I know there have been posts on this subject, but could not locate what I was looking for in the Audit or Lending forums. When trying to caculate the payments streams what do I use for the new TIL format? I have a payment of $741.16 for 1852 days (5/1 arm) then my remaining 300 payments would be based off of what? I used to use the payment streams but now they are not on the new format. Maybe I should not be doing this on a Monday?

You still use the payment streams, we have the processing staff do a screen print off the system for us as it doesn't show on the face of the TIL anymore.

Rules, is absolutely right. I have to constantly remind our Audit department that yes the APRWIN program works just fine, but the payment stream on the TIL CANNOT be used in the calculation, you have to either get the payments from the system or figure them out based on the note etc.

Has anyone seen examiners run into this yet? Our last exam was shortly after the change so they only pulled 1 file with the new disclosure (which we had to explain to them because they were unaware of the change). Are they asking for system payment streams or are they calculatin them themselves?

It will be interesting to see what the examiners do. Even if they recalculate the full payment schedule, they will want to see the schedule you used in order to compute the TOP, FC, and APR. Section 226.25 requires you to retain evidence of compliance with these calculation/disclosure requirements.