I know this has been discussed before, but didn't recall if I ever noticed where the confusion was resolved. Looking at the revised TIL's so much with the MDIA changes had me wondering...

Section 128(b)(2)(B) of TILA, Reg Z, and the Official Staff Interpretations are unclear to me as to whether the statement “You are not required to complete this agreement merely because you have received these disclosures or signed a loan application” must be in the final disclosures, as opposed to just the early disclosures. It seems to me that the statement does not make sense in the final disclosures, but the wording of the TILA and the Official Staff Interpretations could be read to require the statement in all disclosures. Reg Z 226.19(a)(4) though could be read to only require the statement in early disclosures.

Is it required for just the ETIL, and if so, would it hurt to be on the final?

It's only required for the ETIL but there is no harm if you, and I think most of us do, include it on the final.

Thanks Dan!

So glad you all had this conversation. We just had this "cited" in a third party review since that statement is also made on our final TILs. It's hard-coded by the vendor and not something we can change.