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#186118 - 05/03/04 02:50 PM Need help with TIL Disclosure
Anonymous
Unregistered

Hi,

Our lending dept. closed a loan in which the borrowers decided they did want credit life insurance at the closing. Do we need to issue updated adjusted dislosures? (The price was given to them at the closing, but not typewritten on the form ahead of time).

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Lending Compliance
#186119 - 05/03/04 03:07 PM Re: Need help with TIL Disclosure
redsfan Offline
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redsfan
Joined: Dec 2000
Posts: 3,455
The Pennant Race
First: Is this single premium or monthly payment credit life?

Second, was the amount of the single premium included in the amount financed providedto the borrower? If the insurance had monthly premiums, were they included in the payment stream info? Were the premiums included in the finance charge?
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#186120 - 05/03/04 03:22 PM Re: Need help with TIL Disclosure
Anonymous
Unregistered

It appears to be a monthly payment for a term of 10 years. The amount of the monthly cost was handwritten on the TIL, but was not added to the amount financed. The application was sent to the insurance company for approval, therefore, no funds were collected at the closing for the insurance premium. If they receive approval, the payments will be collected monthly along with the regular mortgage payment, and put into a separate account in which the bank will pay the insurance when due. (newbie compliance officer here - thanks for the help!)

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