Our outside QC company is siting us for not writing the MDIA statement "You are not required to complete this agreement merely because you have received these disclosures or signed a loan application" on the final TIL. 1) Our Doc Prep company does not even have a way to put this on the docs and 2)I can't find it in the reg that it is required. Their argument is that the number change, even slightly,from the initial TIL, so that we need to have it on there. Can you advise?

Your QC company is nuts.

The regulation allows it to appear on any final TIL, it does not require it.

Have them show you the citation that supports their claim.

The Notice is required on the ETIL disclosures per F. Notice—§226.19(a)(4) The MDIA requires that the early disclosures contain a clear and conspicuous notice containing the following statement: ‘‘You are not required to complete this agreement merely because you have received these disclosures or signed a loan application.’’

It is not required to be a part of the final TIL.

We must be using the same QC company. Our exception list just came back and it stated the same thing!