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Home Equity Loan - Final TIL
Answer by Randy Carey, BOL Guru
Guru Bios
Question: Is a final TIL required on a fixed rate home equity loan?
Answer: Since a home equity loan is typically secured by a secondary lien and happens after a customer has already purchased their home, the answer is generally, "No." Early TIL disclosures only apply to residential mortgage transactions when a security interest is created or retained in the consumer's principal dwelling to finance the acquisition or initial construction of that dwelling.
Unless the home equity loan is being used to finance the acquisition or initial construction of the dwelling, there would be no need for an "early" truth in lending disclosure.
First published on BankersOnline.com 3/24/08
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