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#1219448 - 07/20/09 08:43 PM Triage Materials - TIL Timing Example Question
pacar Offline
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Joined: Jul 2007
Posts: 320
Regarding redisclosure and timing of the early TIL's...

I am not understanding an example which was provided at the Triage event:

Example 4 states that an early TIL was mailed on 8/12/09. A problem with the APR was discovered on 8/13/09 and a revised disclosure was delivered in person on the 13th. Consummation could occur on 8/18 (by which time both the 3-day period after receipt of the revised disclosures and the 7-day waiting period will have expired).

I don't understand how consummation could occur on the 18th. I thought that both the original 7-day waiting period and the new 3-day waiting period needed to expire before the loan could be closed.

What am I missing?

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Lending Compliance
#1219458 - 07/20/09 08:51 PM Re: Triage Materials - TIL Timing Example Question pacar
waldensouth Offline
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waldensouth
Joined: Nov 2001
Posts: 7,983
FINALLY ABOVE the gnat line
Those 2 time periods can run concurrently - they don't have to be back to back.
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"Once you learn to read, you will be forever free."

- Frederick Douglass




My Opinion Only.

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#1219470 - 07/20/09 08:59 PM Re: Triage Materials - TIL Timing Example Question pacar
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,351
Originally Posted By: pacar
Regarding redisclosure and timing of the early TIL's...

I am not understanding an example which was provided at the Triage event:

Example 4 states that an early TIL was mailed on 8/12/09. A problem with the APR was discovered on 8/13/09 and a revised disclosure was delivered in person on the 13th. Consummation could occur on 8/18 (by which time both the 3-day period after receipt of the revised disclosures and the 7-day waiting period will have expired).

I don't understand how consummation could occur on the 18th. I thought that both the original 7-day waiting period and the new 3-day waiting period needed to expire before the loan could be closed.

What am I missing?


I agree with you. Seven days from 08-12 would be 08-20. Three days from re-disclosure (08-13) would be 08-17. So consummation could not possibly take place until 08-20.
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The more you sweat in training, the less you bleed in battle.......

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#1219479 - 07/20/09 09:08 PM Re: Triage Materials - TIL Timing Example Question swiggles
pacar Offline
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Joined: Jul 2007
Posts: 320
I could not figure out how it could be anything but the 20th. It's nice to know I'm not crazy...

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