QUESTION: Who is responsible for the TIL disclosures when working with a broker?
ANSWER: The disclosures are the responsibility of the creditor. The creditor is the party that makes the decision and
advances the money. Reg Z defines the creditor as the party to whom the obligation is initially payable. That is usually the lender and not the broker.
As a practical matter, don't rely on a broker to deliver this and get it right.
Many years ago, there was the thought of having real estate brokers provide early TIL disclosures, however they
dodged that bullet and the earlies remain the responsibility of the creditor/lender.
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