I have located a single incident where the TILA disclosure was not produced. (There is a critical warning on the loan checklist from the vendor software.- it was just missed.)

What do we do now?

I've been told that if you don't provide a TIL with a disclosed APR, that the loan rate becomes the APR which means you would have to refund any pre-paid finance charges.

In the back of my pea brain, seems one of the gurus said that is incorrect....that you just have a TIL violation but no reimbursement.

Anyone?

I think the last three items in this prior posting (particularly Dan's and KB's may shed some light:

http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1368877

Thanks. It isn't as bad as I thought it might be!