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#1660848 - 02/06/12 01:33 PM Material disclosures in a rescindable transaction
1995Banker Offline
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Joined: Apr 2002
Posts: 241
If a consumer has a security interest in the property in a rescindable transaction, but is not on the loan, they recieve 2 copies of the rescission notice.

Could someone clarify it they are required to recieve a copy of the material disclosure (TIL)as well, even though they are not on the loan?

Thank you!

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Lending Compliance
#1660857 - 02/06/12 01:30 PM Re: Material disclosures in a rescindable transaction 1995Banker
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
General disclosures under Z:

(d) Multiple creditors; multiple consumers. If a transaction involves more than one creditor, only one set of disclosures shall be given and the creditors shall agree among themselves which creditor must comply with the requirements that this regulation imposes on any or all of them. If there is more than one consumer, the disclosures may be made to any consumer who is primarily liable on the obligation. If the transaction is rescindable under Sec. 226.23, however, the disclosures shall be made to each consumer who has the right to rescind.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1660873 - 02/06/12 02:09 PM Re: Material disclosures in a rescindable transaction 1995Banker
1995Banker Offline
100 Club
Joined: Apr 2002
Posts: 241
Thanks Kathleen!
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