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#1497144 - 01/19/11 07:21 PM HELP FAST - Please
upstateNY Offline
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Joined: Apr 2003
Posts: 933
New York State
We are still trying to get our new TIL's ready for 01/30. The most recent version sent to us by our vendor DOES NOT include a place for the borrowers to sign the TIL. I've been in banking a very long time and have always seen a signature on a TIL.

I'm on a webex right now and can't research. The vendor needs to know today if we will require the borrowers to sign our TIL's, requiring additional programming. Please, does anyone know quickly whether sigs are required under Z on the TILS?

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Lending Compliance
#1497166 - 01/19/11 07:46 PM Re: HELP FAST - Please upstateNY
MN Banker Offline
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Posts: 980
Signatures are not required by regulation on the TIL

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#1497170 - 01/19/11 07:49 PM Re: HELP FAST - Please upstateNY
RR Joker Offline
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The Swamp
Technically, no...but most FI's want a signature because of the legality of the document.
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#1497176 - 01/19/11 07:53 PM Re: HELP FAST - Please upstateNY
VRV Offline
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Posts: 173
Reg. Z does not require that the disclosure be signed. However, most lenders have a policy that the customer sign the disclosure as a way of proving that the customer received it.

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#1497184 - 01/19/11 07:59 PM Re: HELP FAST - Please RR Joker
upstateNY Offline
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New York State
Originally Posted By: RR joker
Technically, no...but most FI's want a signature because of the legality of the document.


Thanks, do you feel that we place ourselves at risk by not having them signed? I've never seen a TIL without a sig line..and I've been in banking for many years.

I don't like to ask for sigs if not required, as it's one more item that can be picked up as an audit exception. But this seems alien to me.

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#1497188 - 01/19/11 08:00 PM Re: HELP FAST - Please upstateNY
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Many banks do NOT require a signature line. It is up to the bank.
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#1497348 - 01/19/11 10:52 PM Re: HELP FAST - Please RR Joker
QCL Offline
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Posts: 6,259
NW IL
Originally Posted By: RR joker
Technically, no...but most FI's want a signature because of the legality of the document.


We do as a matter of bank policy.
And we would go back to the vendor and ask for it.

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