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#2084756 - 06/22/16 09:40 PM Disclosures - Oral
SallyGirl Offline
Member
Joined: Aug 2014
Posts: 87
Not sure I posted this correctly so will post again...

How would we orally disclose the payment schedule (since it is loan specific) early on in the process? Couldn't we read the details of the payment at the closing before signatures are put to paper?

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#2084792 - 06/23/16 12:57 PM Re: Disclosures - Oral SallyGirl
Minion Offline
Member
Minion
Joined: Jun 2015
Posts: 64
Virginia
You can provide the borrower with a toll free # to call to receive their disclosures or you can provide the details "at the time the borrower becomes obligated"

Section 232.6(a) requires a creditor to provide three categories of information to a covered borrower ‘‘at the time the borrower becomes obligated on the transaction or establishes an account for the consumer credit,’’ namely:
• A statement of the MAPR applicable to the extension of consumer credit;
• Any disclosure required by Regulation Z, which shall be provided only in accordance with the requirements of Regulation Z that apply to that disclosure; and
• A clear description of the payment obligation of the covered borrower, as applicable. A payment schedule (in the case of closed-end credit) or account opening disclosure (in the case of open end credit) provided pursuant to paragraph (a)(2) of this section satisfies this requirement.’’

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#2084793 - 06/23/16 12:58 PM Re: Disclosures - Oral SallyGirl
Minion Offline
Member
Minion
Joined: Jun 2015
Posts: 64
Virginia
Sorry one more note from the Fed Register that is useful:

When orally providing the required disclosures, a creditor may elect to provide the disclosures in person, as the circumstances surrounding the establishment of the transaction or account involving consumer credit may permit, or to provide a toll-free telephone number that the borrower can use for that purpose.

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