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#1876379 - 12/05/13 06:18 PM TIL/MDIA
Jadeblu Offline
Member
Joined: Feb 2010
Posts: 54
Louisiana
I have a loan that was scheduled to close today, they lowered loan amount by $10,000. APR not affected by .125 but finance charge dropped from disclosed amount of $166,808 to $159,607. But finance charge did not increase from disclosed amount by the $100.00 so no new disclosures are necessary, right? If we do redisclose even tho APR not affected, wouldn't we have to wait the 3 days to close?

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RESPA
#1876391 - 12/05/13 06:30 PM Re: TIL/MDIA Jadeblu
RR Joker Offline
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The Swamp
We would not wait for this reason. You can always issue a final TIL at closing. If it's not out of tolerance, there is no waiting period.
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#1876393 - 12/05/13 06:32 PM Re: TIL/MDIA Jadeblu
rlcarey Online
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rlcarey
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Posts: 79,637
Galveston, TX
You don't have to re-disclose. If you do something that is not required under the regulation, it does not suddenly make the regulation apply.

Explaining this to an examiner however would probably be your biggest issue.
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#1899932 - 02/25/14 09:03 PM Re: TIL/MDIA Jadeblu
nikki_compliance Offline
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Joined: Mar 2010
Posts: 520
NM
If I may bring this thread back up, We have a loan where the APR is not within tolerance from ETIL to final due to the fact that we included the homeowners insurance on the GFE but not on the loan, the finance charge went down however the APR went up. Do we have to redisclose? And if so do we redisclose leaving the homeowner insurance out?

thank you.

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#1900254 - 02/26/14 07:20 PM Re: TIL/MDIA nikki_compliance
dblack Offline
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Joined: Feb 2008
Posts: 263
AL
Originally Posted By: nikki_compliance
We have a loan where the APR is not within tolerance from ETIL to final.


Then you must re-disclose the TIL.


Whether or not you re-disclose the GFE would depend on if you have a valid changed circumstance.
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#1900258 - 02/26/14 07:23 PM Re: TIL/MDIA Jadeblu
RR Joker Offline
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RR Joker
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The Swamp
I'm a bit confused...is this affecting the APR because your FI or an affliate sold the insurance and it was required by you with no option (I think that's the only time that affects the APR-no real life experience with it wink ).
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#1903460 - 03/07/14 07:12 PM Re: TIL/MDIA Jadeblu
CMSIngenue Offline
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Joined: Jan 2013
Posts: 150
If the finance charge increased ($100 or $35 depending purchase/refi) between the last redisclosed TIL and the Final TIL (Printed at Docs), does the file have to be redisclosed and a waiting period observed before docs can be drawn?

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