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#1222873 - 07/27/09 05:00 PM Early TIL Multiple Borrowers or Non Borrowing Owne
terpsfan Offline
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Joined: Feb 2007
Posts: 2,058
Are we required to give the early til to all borrowers and non borrowing owners who have rescission rights? If so do the timing requirements apply to these disclosures also?
Last edited by terpsfan; 07/27/09 05:55 PM.
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Lending Compliance
#1222890 - 07/27/09 05:30 PM Re: Early TIL Multiple Borrowers or Non Borrowing Owne terpsfan
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1227595 - 08/05/09 04:19 PM Re: Early TIL Multiple Borrowers or Non Borrowing Owne terpsfan
VRV Offline
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Joined: Jun 2007
Posts: 173
It is my understanding that yes, each person who has the right to cancel the transaction, needs to be provided with their own copy of the early TIL disclosure, just as they are entitled to a copy of the final TIL disclosures. The timing requirements would also apply.

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