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#1711497 - 06/18/12 09:31 PM Inaccurate Final TIL
rachelchri Offline
100 Club
Joined: Aug 2010
Posts: 165
I just finished my Quarterly Compliance Audit for our Real Estate Loans. I came accross a couple of files where the Security Interest disclosure on the Final TIL was inaccurate. What does the law say to do about fixing theses? Do we need a new one signed by the customer?

HELP!

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Lending Compliance
#1711666 - 06/19/12 03:05 PM Re: Inaccurate Final TIL rachelchri
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,333
If underdisclosed, the amount of under disclosure would be a prepaid finance charge. Reg Z states that certain charges (security interest charges) are exempt from pre-paid finance charge if itemized and disclosed. So if you didn't disclose part of the fee, you'll have to consider the extra a PP and check tolerance limits. If you've over-disclosed, you're probably OK.
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