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#69615 - 03/25/03 05:10 PM FED BOX - Failure to identify security interest
OnTheEdge Offline
Diamond Poster
Joined: Apr 2002
Posts: 1,677
SmallTown, USA
Just completed a compliance review on consumer loans. (No Real Estate Transactions included.) One market failed to indicate our security interest in the FED BOX. The market is wanting to re-disclose in an attempt to correct. I'm fairly familiar with APR and Finance Charge errors, but don't really know how the bank should handle. Basically, I usually state that Reg Z is all about disclosure and the violation stands. Any comments are appreciated.
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Lending Compliance
#69616 - 03/25/03 05:12 PM Re: FED BOX - Failure to identify security interes
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
See Section 130(b) of the TILA.
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...gone fishing.

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#69617 - 03/26/03 12:02 AM Re: FED BOX - Failure to identify security interest
Lucy Griffin Offline

Diamond Poster
Lucy Griffin
Joined: Nov 2000
Posts: 1,544
There is nothing wrong with redisclosure, but you can't change the numbers. You have to stand by the numbers you disclosed and make restitution if they are incorrect. As for security, it doesn't affect the numbers.

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