We had an opinion from FDIC last year (as well as our online mortgage app provider) in the case of a mortgage application with multiple borrowers who have the right to rescind - because Reg. Z says each of them must receive a separate copy of the TIL, for an online mortgage application, you must mail the early TIL to the co-applicant(s).

Are others of you doing this?

No, we give all parties the final TIL (but then we always prepare a final and never rely on the eTIL)

Yes, we mail out a copy of the preliminary TIL (the same one they are assumed to have viewed online) to the co-borrower only, specifically addressed to them on the envelope.

It has nothing to with the final TIl, imo.

I agree. All who are entitled to rescind must receive a copy of the ETIL. Review 226.17(b) and (d).

Thank you! Yes, I agreed it was required, especially after the formal opinion. Just got the line "we are the only ones doing this...are you sure it's really required? It's a lot of extra work..." You know how it goes.