We are working on completing the new disclosures for the upcoming MDIA rule effective 1/30/11. We are having trouble determining how to complete the Early TIL for construction loans. We use Jack Henry streamline. Is there any guidance out there that anyone is aware of that will assist us in making sure this form is completed properly for compliance? Since it checks that the form is the preliminary (early TIL) or the final (final TIL)does the regulation still reequire us to put an "e" beside the finance charge, total payments, etc...???

I believe the "e" is still required.

I'll second that.

Thanks

Were you able to get the "e" on the early TIL? Was just notified by operations that it isn't on our form either. We are also JHenry. My original thought was that they weren't using the "early" form. Haven't heard back from them on that for sure.

We are JH, and we have an "e". From my understanding from our platform supervisor, some was already on it, and some you can place yourself. Don't know the exact details on all that. I did look at some of the proto's, however...they are using a capital "E" and it almost blends into the other info on the template.

Thank you.... that was quick.

Are those who use Jack Henry also using Wolters-Kluwar e-forms? It seems like they have 15 versions of the TIL but with little or no explanation of which form to use when.

Does anyone have a chart or tools or any some kind of guidance materials to help with doc selection and training?

Yes. And JH only picked like 7 of them, I think. I think WK has over 30 to choose from.

Did you read WK's January 2011 Release Notes? They describe which VMP form applies for the tabular disclosures. If you don't have the release notes, which you may not have if you don't use their software products, then I would suggest contacting JH since you are using them in connection with WK's forms. I would assume they would also issue release notes for any software updates.

We've gotten along okay with what JH decided on except for in one instance where I would prefer the separate the interest payment and the principal payment.

For instance, when you customer is paying a set amount of principal plus the interest each month. There's no really good way to disclose those. Same with interest monthly with scheduled principal reductions...no way to disclose it.