Skip to content
BOL Conferences
Thread Options
#1684678 - 04/02/12 03:02 PM TIL Redisclosed When Not Required - Wait 3 Days?
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Our vendor packages the GFE and TIL together when redisclosing, even if only one is required. Am I correct in thinking that we don't have to comply with the MDIA waiting period to close the loan even though a new TIL was delivered? The APR was within tolerance and redisclosure of the TIL was not required. I'm basing my opinion on this (see quote below), but I've found conflicting opinions in prior threads.

"It is important to note that the three-business-day waiting period for corrected TILA disclosures applies only if the changes occurred as a result of an APR error. Otherwise, only the corrected disclosure is required, and lenders do not have to wait three business days before consummation."
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

Return to Top
Lending Compliance
#1684689 - 04/02/12 03:15 PM Re: TIL Redisclosed When Not Required - Wait 3 Days? Kelsey D
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
If your TIL is not out of tolerance, you do not have a waiting period. Think of it as a Final TIL, many banks provide one needed or not.
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#1722820 - 07/24/12 06:15 PM Re: TIL Redisclosed When Not Required - Wait 3 Days? Kelsey D
TattChica Offline
100 Club
Joined: Oct 2007
Posts: 151
Va Beach, VA
In the situation of a re-disclosed TIL is the 3 days assuming that you are electrconically delivering the new doc? What if you dont have e-doc delivery, is the wait 6 days?
"I used to have a handle on life, but it broke!"

Return to Top
#1723002 - 07/25/12 12:43 PM Re: TIL Redisclosed When Not Required - Wait 3 Days? TattChica
Carolina Blue Offline
Platinum Poster
Carolina Blue
Joined: Jul 2005
Posts: 961
Lost in a regulatory fog
Sort of. The borrower must be given 3 business days to review the revised disclosure before closing, so it just depends on when you can prove the borrower received the disclosure. E-Sign or in-person gives you an exact date so you can count 3 days from that date. The OSC says that if you mail the disclosures you can assume the borrower gets them on the 3rd day. Add the 3 waiting days and that's where the 6 business day waiting period comes from.

Return to Top

Moderator:  Andy_Z