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#1269763 - 10/20/09 04:40 PM Help I asked this before but I need HELP!!!!!!!!!!
donna.raisor Offline
Platinum Poster
Joined: Sep 2004
Posts: 554
We have fees that are considered to be pre-paid finance charges which are a processing fee and coupn book fee. The loan that is being done all the fees are being financed my question is wouldn't that be included in the amount financed on the TIL? Becuase when we did the loan docs it is deducted from the amount financed, see I am confused.

2nd question:
If we have to redisclose the early TIl on a RE loan do you change the date on the redisclosure? For ex: the Application date was done 09/30/2009 and we provided disclosures that day now things have changed and we have to redisclose the TIL what day do I use so I can document for the examiners?

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#1270124 - 10/20/09 08:38 PM Re: Help I asked this before but I need HELP!!!!!!!!!! donna.raisor
blvsinangels Offline
Gold Star
Joined: Aug 2003
Posts: 372
Don't know on the first one. Second question, you need to put the current date on the new TIL. This may restart your 'count' for when you can close the loan..

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#1270192 - 10/20/09 09:25 PM Re: Help I asked this before but I need HELP!!!!!!!!!! donna.raisor
ktac MITCH Offline
Diamond Poster
ktac MITCH
Joined: May 2005
Posts: 1,813
Giant side of TX
Originally Posted By: donna.raisor
We have fees that are considered to be pre-paid finance charges which are a processing fee and coupn book fee. The loan that is being done all the fees are being financed my question is wouldn't that be included in the amount financed on the TIL? Becuase when we did the loan docs it is deducted from the amount financed, see I am confused.

The Reg Z term "Amt Fin" can be confusing, try to think of it as what net funds did the borrower walk out the door with.
ie loan for $1,000 but you have PPFC of $100, so the borrower is only walking out the door with $900 & Reg Z then uses that 'net' to calculate the APR from.

2nd question:
If we have to redisclose the early TIl on a RE loan do you change the date on the redisclosure? For ex: the Application date was done 09/30/2009 and we provided disclosures that day now things have changed and we have to redisclose the TIL what day do I use so I can document for the examiners?
To prove your re-disclosure was received by the borrower at least 3 Bus Days prior to loan closing you need to use the date the re-disclosure is generated.
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