Our loan department wants to run a promotion of waiving closing costs. Of course, they also want to recoup these costs if the customer pays the loan off within 24 months.

I know this is not a "Prepayment Penalty" for purposes of HOEPA and Points & Fees. However, is it a Prepayment Penalty to be disclosed on the TIL?

If it is not a "Prepayment Penalty" on the TIL, how do we disclose to the customer the potential cost of paying off the loan in 24 months. Is only agreed to in the Note?