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#2096297 - 08/31/16 04:03 PM Toll free number - o.k. To provide at closing?
SaaL Offline
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Joined: Mar 2008
Posts: 294
The Texas Hill Country
I haven't seen this specifically addressed in the threads - sorry if I've overlooked. But if I"m reading the rule correctly, we can provide the 800# either on the application form itself OR on the written disclosure that we are providing at closing.....so if we use the second alternative, we go to closing, providing the written MAPR and Reg Z disclosures to satisfy the "in writing" requirement; and we can provide the 800# at the same time - likely on the MAPR written disclosure. So the customer wouldn't get the # until closing but they could stop the closing and make the call (since they're supposed to receive this prior to becoming obligated) and then continue with the closing if they're satisfied. Does that sound about right? Seems kind of illogical but that's really nothing new. wink
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#2096298 - 08/31/16 04:11 PM Re: Toll free number - o.k. To provide at closing? SaaL
ScoutLaRue Offline
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Joined: Jul 2016
Posts: 73
That's how I'm reading it as well... I agree--does not make much sense to provide at the closing. The dod consumer credit disclosure provided by our LOS system has a section to provide the toll free number right on it under the payment schedule and MAPR model info.

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#2096299 - 08/31/16 04:12 PM Re: Toll free number - o.k. To provide at closing? SaaL
SaaL Offline
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Joined: Mar 2008
Posts: 294
The Texas Hill Country
Thanks Scout. Our LOS is doing the same.
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#2099349 - 09/20/16 02:28 PM help with toll free number SaaL
pjs Offline
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pjs
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Help. I have just returned from work from being off for 8 months and have been reading, and reading and trying to get back into the swing of loan compliance. Can someone help me with the MLA toll free number and extension needed to be on the disclosure? Or where to find the number. Thank you so much.

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#2099354 - 09/20/16 02:51 PM Re: help with toll free number pjs
RR Sarah Offline
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RR Sarah
Joined: Mar 2004
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Up North
The toll free number would be your bank's.
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#2099357 - 09/20/16 02:58 PM Re: help with toll free number RR Sarah
pjs Offline
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pjs
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oHiO
Thanks so much!

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#2100235 - 09/23/16 10:13 PM Re: Toll free number - o.k. To provide at closing? SaaL
Betty Banker Offline
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Joined: Sep 2015
Posts: 53
I am still trying to figure out if we will establish a toll free number for covered borrowers to call. Must the call go right to the script providing the disclosure? We have a toll free number but we would have to provide an extension for the borrower to dial in order to get to the disclosure. During business hours, the call would have to be transferred. Is anyone else using an extension or just setting up a new number which goes right to a recorded message?

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#2100253 - 09/24/16 03:24 PM Re: Toll free number - o.k. To provide at closing? SaaL
Andy_Z Offline
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I assumed (dangerous, I know) that if you have an established 800 line and are using generic disclosures, an extension to a recorded message would be used. It seems the simplest and most consistent way to comply.
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