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#207843 - 07/06/04 01:52 PM Creditor's Address on Right of Rescission
JMB Offline
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JMB
Joined: Mar 2002
Posts: 59
Michigan
I know that Reg Z - 226.23 (b) (1) (for a closed end loan) requires that the creditor's address be listed on the ROR. I also know that an agent's address may be included as additional information.

I have been seeing several RORs that ONLY list the agent's address (generally a title company).

I think that is wrong - does anyone agree?

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Lending Compliance
#207844 - 07/09/04 11:02 AM Re: Creditor's Address on Right of Rescission
JMB Offline
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JMB
Joined: Mar 2002
Posts: 59
Michigan
Does anyone have any thoughts on this?

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#207845 - 07/09/04 12:20 PM Re: Creditor's Address on Right of Rescission
Bartman Offline
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Bartman
Joined: Oct 2000
Posts: 1,191
Springfield
I agree with you. The section you cite states address of the creditor. Unless the title agent is also the creditor, you need the bank's address at a minimum.
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Opinions are Bartman's, not those of my employer. "A noble spirit embiggens the smallest man."

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#207846 - 07/09/04 01:03 PM Re: Creditor's Address on Right of Rescission
redsfan Offline
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redsfan
Joined: Dec 2000
Posts: 3,455
The Pennant Race
I agree with Bart. While the Reg and Commentary permit the inclusion of the title company's address as the agent to receive the rescission for the creditor (the title company has the $$, so they need to receive the notice first), the name and address of the creditor also appear to required.
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The opinions expressed here are personal and do not represent opinions of my employer.

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#207847 - 07/09/04 06:32 PM Re: Creditor's Address on Right of Rescission
JMB Offline
Member
JMB
Joined: Mar 2002
Posts: 59
Michigan
Thanks guys - I appreciate the response - it seemed so easy, but why are so many getting it worng????

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