biz - you can unprotect the file and make the changes yourself to fit your needs. I did just that for our shop.

The tool was created by another banker voluntarily, and I did not think it was fitting to further ask him to modify it just to suit me. (For example, we too will be requiring this in the files - which are scanned - and the purple does not scan or convert well, so I changed the color.)

I also reprotected the sheet to only allow users in my bank to modify the date field cells. They cannot select any other cells on the sheet.

And maybe this is beyond my capabilities, I guess there's no maybe. But when the 3 days for the initial disclosure fall over like Columbus day, and we are open to carry on . . .yadda, yadda, yadda, the calculator does not count any federal holiday. I could be crazy, (definate possibility) but I thought the count for the initial disclosure and the count for the Reg Z day count were difined differently. So I would also have to effect that somehow right?

I'm confused, and clearly I'm reading something wrong. RR joker's post sounds like they said if it's overstated then re-disclosure is required. But David's post sounds like an overstatement doesn't need to be redisclosed?

Read the last part of David's response:

"...if it complies with §226.22."

Then go to my post 1220708 and then to David's post 1220727.


An overstated APR is not automatically considered accurate and if the APR quoted on the ETIL is not accurate then it must be redisclosed.

In a nutshell...yes.

Oh boy. I had to read and re-read the reg about 10 times but I think I finally got it! Thanks Dan!

quoted from David's post a couple pages back from the San Fran conference:


This apparently was only for RofR purposes...as detailed in 226.17

(d) Multiple creditors; multiple consumers. If a transaction involves more than one creditor, only one set of disclosures shall be given and the creditors shall agree among themselves which creditor must comply with the requirements that this regulation imposes on any or all of them. If there is more than one consumer, the disclosures may be made to any consumer who is primarily liable on the obligation. If the transaction is rescindable under Sec. 226.23, however, the disclosures shall be made to each consumer who has the right to rescind.

YOu know, I had about come to the "simple" conclusion that if RESPA applies, an eTIL will now be required...but there are still exceptions to this, aren't there?

the example a few pages back about son borrowering against mom/dad's home, personal purpose..would still require a GFE and HUD 1, but because it's not a loan on a dwelling of THE consumer's (son's), eTIL wouldn't be required. Final TIL and RofR would, however.

agree?

The new Reg Z and HELOC rules are out!!!!

http://www.federalreserve.gov/newsevents/press/bcreg/20090723a.htm

The NPRM for HELOCs is 660 pages in non-Federal Register format.

The NPRM for closed-end credit is 674 pages in non-Federal Register format.

Both proposals indicate that comments will be accepted for 120 days from the date of publication in the Federal Register.

http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20090723a1.pdf This is a 2 page highlights document that was referenced in the press release.

Happy reading!!!!

And people ask me why I am still smoking!!! I think its time to take up drinking as well. No rest for the weary.

WARNING SYSTEM OVERLOAD
I think I just reached my limit - I am going to ignore this and just pick up the "Scoop" from all the gurus, and masochists who take time to read all this **@&$*#%

Agree.

That was my reaction as well! We are so busy trying to get the final stuff trained on and implemented, I don't think I'll have time to read through all that, digest it, determine what I like and don't like, then comment on it. I'm just going to pray that for once they make changes that are good changes for everyone. Maybe the only comment we need to make is, "You should only require all these changes for those who made the risky, crazy mortgages that led to all the problems." Ya, right! Grrrrrr.....

Misery loves company my *#*$)! My brain is numb and I'm doing that nervous giggle thing again.
Just took a quick look and decided I'm going over to sit in the corner next to ktac MITCH and wait for the rest of you to decipher this.

Is each own disclosure on the loans that are rescindable or all loans subject to the ETIL? Thanks.

Truff
Misery loves company, so WELCOME. Come on over to the corner with me, this might even convience me to start drinking something harder than Dr. Pepper

^^^ I'm with you two but need to get it in my head and it's getting there but then to make sure our compliance overseer'er sees it the same way.

I think I will read the 2 page summary and wait too. I'll read it when it is final (or listen to a webinar)!!

Probably should start a new thread for that subject or this one will be 100 pages soon . . . .

Noooo....this is why I rely on you.

I have read thru all 55 pages of this thread, but have not seen a specific comment about whether or not the new statement about the consumer not being required to complete the agreement should be in the "fed box" or not in the "fed box." Anyone have that answer?

Ours is in the Fed Box - Wolters Kluwer Financial Services - does ours.

It's the last statement in the Fed Box.

On "the call" yesterday the San Fran Fed Reserve people said it should not be in the Fed box....