Where can I find in the regs that an Early TIL is not required on a refinance? Part 226.19 of Reg Z states that the Early TIL is required for Mortgage Transactions subject to RESPA. Part 3500.2 of RESPA defines a Federally related mortgage loan as......Any loan that is secured by a first or subordinate lien on residential real property, including a refinancing of any secured loan on residential real property...... I have had several people tell me that an Early TIL is not required on a refinance and I've even seen it on some lender tools, I just can't seem to reconcile that to the regulations and it's drving me crazy...Help!

That was prior to the MDIA changes....an early TIL IS required on a refinance now as long as it isn't a timeshare or HELOC.

Under the old rules the ETIL was only required for a Residential Mortgage Transaction, which is defined at 226.2(a)(24), subject to RESPA. Refinancings and most subordinate lien loans did not meet that definition therefore they were exempt from the ETIL.

With the MDIA changes the wording in 226.19(a) was changed and the word "Residential" was removed. Now any mortgage transaction subject to RESPA requires an ETIL.

Thank you so much. Maybe I'm not as crazy as I thought!