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#2192635 - 09/14/18 04:30 PM Re: Who must receive the LE and CD? Kim M.
Bville Offline
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Bville
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Out West
As of 10/1 only consumers to whom credit is extended will be listed as "Borrowers" on the CD. See 1026.38(a)(4)-4

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TRID - TILA/RESPA Integrated Disclosures Rule
#2192645 - 09/14/18 05:26 PM Re: Who must receive the LE and CD? Kim M.
John Burnett Offline
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Cape Cod
And, because that added comment (comment 38(a)(4)-4) was effective 10/10/17 (compliance optional until 10/1/18), you can follow it now. Your "new" information, Nick, is late in coming to you. It reflects TRID 1.0.

Under TRID 2.0, "consumers" who are non-obligors but have a rescission right because of their ownership of the property and their use of the property as their principal residence, still must receive a copy of the closing disclosure three business days before consummation, but they should not be listed as a "borrower" on the closing disclosure.

And welcome to BOL's Discussion Forums!
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#2192652 - 09/14/18 05:51 PM Re: Who must receive the LE and CD? Kim M.
RR Joker Offline
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I am so glad this is changing as it's always been a point of contention...
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#2192663 - 09/14/18 06:34 PM Re: Who must receive the LE and CD? Kim M.
mdog76 Offline
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Tagging along to this thread instead of making a new: Would someone who is putting up collateral for a loan but NOT an obligor to the loan need to receive a copy of the CD? This is not a primary residence or rescission loan but is TRID.
Last edited by John Burnett; 09/14/18 06:57 PM. Reason: missing word
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#2192666 - 09/14/18 06:43 PM Re: Who must receive the LE and CD? Kim M.
RR Joker Offline
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The Swamp
No
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#2192667 - 09/14/18 06:44 PM Re: Who must receive the LE and CD? Kim M.
RR Joker Offline
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The Swamp
[I think you meant NOT an obligor]
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#2192669 - 09/14/18 06:50 PM Re: Who must receive the LE and CD? Kim M.
mdog76 Offline
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I did, not an obligor.

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#2192671 - 09/14/18 06:56 PM Re: Who must receive the LE and CD? Kim M.
John Burnett Offline
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John Burnett
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The regulation doesn't require that such an individual get a copy of the disclosures.
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#2195088 - 10/10/18 03:00 PM Re: Who must receive the LE and CD? Kim M.
Comply Offline
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Joined: Jul 2015
Posts: 33
Help with this scenario:
Purchase Transaction, is the Non-Obligor on title to get a copy of the CD?

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#2195098 - 10/10/18 03:36 PM Re: Who must receive the LE and CD? Kim M.
Adam Witmer Online
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Joined: Sep 2010
Posts: 2,630
As rescission will not apply, no, they are not entitled to a CD.
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All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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