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#484931 - 01/17/06 11:00 PM Questions about 226.32 (TILA)
02bonne Offline
Platinum Poster
Joined: Nov 2005
Posts: 620
I'm researching this disclosure and need some guidance.

1. If this section doesn't cover residential mortgage transactions, I assume it just covers loans secured by the individuals dwelling for miscellaneous purposes?

2. Does anyone know where I can get a sample disclosure template?

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Lending Compliance
#484932 - 01/17/06 11:09 PM Re: Questions about 226.32 (TILA)
GreatBlue Offline
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GreatBlue
Joined: Feb 2003
Posts: 2,362
Colorado
You need to read the definition of "residential mortgage transaction" in 226.2(a)(24). It is a very important definition, and applies to lots of things in Reg. Z.

Look at Appendix H-16 for a model.
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#484933 - 01/18/06 03:20 PM Re: Questions about 226.32 (TILA)
02bonne Offline
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Joined: Nov 2005
Posts: 620
We currently disclose all of this information, just not all on one page. Do the disclosure requirements in subsection C have to be all on one page as in appendix H-16?

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#484934 - 01/18/06 03:43 PM Re: Questions about 226.32 (TILA)
GreatBlue Offline
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GreatBlue
Joined: Feb 2003
Posts: 2,362
Colorado
The only format requirements for that disclosure are that it be "clearly and conspicuously in writing, in a form that the consumer may keep". You'd need to be careful that separating the disclosure information doesn't result in it no longer being clear and conspicuous.

I'm curious though, why don't you have it on one page? Is it mixed in with other things? Generally the timing requirements of this particular disclosure (3 business days prior to loan closing) mean that it is given by itself.
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Opinions are mine and not necessarily my employer's.

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#484935 - 01/18/06 05:27 PM Re: Questions about 226.32 (TILA)
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Quote:

2. Does anyone know where I can get a sample disclosure template?




PM me your email address and I'll send you a sample disclosure in Word format.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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