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#1361377 - 03/20/10 01:27 PM ARM's and the Early TIL 7/30/09 Changes
Compliance Newbi Offline
Junior Member
Joined: Mar 2010
Posts: 39
Illinois
When we disclose an early TIL for an adjustable rate mortgage, we use the most recent available corresponding Treasury index figure when calculating the second payment stream for the APR. If the loan closed several weeks later and we use the most recent index figure, the APR can change over the 1/8 tolerance. Would we be able to give the new TIL at closing, and use the 3 day Right of Recission as the 3 day waiting period before consummation?

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#1361379 - 03/20/10 03:27 PM Re: ARM's and the Early TIL 7/30/09 Changes Compliance Newbi
Here4Life Offline
100 Club
Joined: Feb 2010
Posts: 116
No. We have almost the same problem. Our index changes on the first of every month which may affect our APR by more than 1/8%. Therefore, it is very risky to have a closing the first week of the month. Because if you have to redisclose the ETIL on the first, then you must wait 3-6 days (depending on delivery mehtod) before you can close.

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#1361382 - 03/20/10 03:52 PM Re: ARM's and the Early TIL 7/30/09 Changes Compliance Newbi
Compliance Newbi Offline
Junior Member
Joined: Mar 2010
Posts: 39
Illinois
Thanks for your reply. I didn't think we could use the Right of Recission as an out, but when I read the information I have on the changes, it said 3 days prior to consummation which can be taken as the consummation taking place after the Right of Recission.

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#1361415 - 03/21/10 06:12 PM Re: ARM's and the Early TIL 7/30/09 Changes Compliance Newbi
jlroberts Offline
Diamond Poster
jlroberts
Joined: Sep 2009
Posts: 1,574
Ohio
We use an index that changes every Monday as well as an index that changes on the 15th of every month and have not had to redisclose or delay a closing due to an index rate change.

http://www.bankersonline.com/forum/ubbth...453#Post1301453

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