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#1264020 - 10/08/09 07:35 PM Revised TIL question
AuditorK Offline
Platinum Poster
Joined: Feb 2003
Posts: 962
PA
Could someone please help a newbie with a Reg Z question?

Early TIL disclosures are given at application for a home purchase. Three weeks later the sales price of the home drops and the APR changes by more than 1/4%. Do we need to provide a revised TIL and wait 3 days before the loan can close?

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Lending Compliance
#1264196 - 10/08/09 09:55 PM Re: Revised TIL question AuditorK
OldSchoolBanker Offline
Platinum Poster
Joined: May 2005
Posts: 657
FL
I am not a Board Guru but I can provide our procedure related to this situation. If this were our loan, YES we would require redisclosure of a revised TIL and wait the appropriate days prior to closing. This is one of the events that can adversely impact the closing.

Lately, low appraisals have been causing our loan amounts to drop and we have had this scenario unfold.

Good Luck!
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Old School Banker

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#1264224 - 10/08/09 10:29 PM Re: Revised TIL question OldSchoolBanker
KTMiteComply Offline
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KTMiteComply
Joined: Jul 2007
Posts: 3,298
only if I want to....
We have just had a similar issue. We have a loan where the Sales Contract states seller to pay for owners Title search, examination & related charges - The Atty puts the seller paying the Atty Fees - it changes the APR from 5.05 to 5.56..... we would have to redisclose...right? I just don't understand why the closing atty would put this in Atty Fees? Why not in Title work for seller pay? Then we would be fine....

Any thoughts or suggestions?
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Trust in the Lord with ALL your heart...Prov 3:5-6

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#1264311 - 10/09/09 01:06 PM Re: Revised TIL question KTMiteComply
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,707
Bloomington, IN
Review 226.4(c)(7) and its Commentary. Generally, depending on the nature of the fee, in a real estate transaction attorney fees are not finance charges.
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The opinions expressed are mine and they are not to be taken as legal advice.

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