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#1531231 - 04/04/11 07:02 PM Program Disclosures
Patricia Offline
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Joined: Mar 2011
Posts: 327
Kansas
I am looking at a loan file and the program disclosure caps agree with the upfront TIL however the caps on the Final TIL are not the same as on the program disclosure. Should we have given a new program disclosure?

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Lending Compliance
#1531315 - 04/04/11 08:41 PM Re: Program Disclosures Patricia
Patricia Offline
Gold Star
Joined: Mar 2011
Posts: 327
Kansas
bump

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#1531431 - 04/05/11 02:22 PM Re: Program Disclosures Patricia
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 77,277
Galveston, TX
Yes

226.19(b)(2) Variable-rate loan program defined. i. Generally, if the identification, the presence or absence, or the exact value of a loan feature must be disclosed under this section, variable-rate loans that differ as to such features constitute separate loan programs. For example, separate loan programs would exist based on differences in any of the following loan features:

C. The presence or absence of, and the amount of, rate or payment caps.
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#1531505 - 04/05/11 03:48 PM Re: Program Disclosures rlcarey
Patricia Offline
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Joined: Mar 2011
Posts: 327
Kansas
Thanks.

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