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#1651162 - 01/13/12 09:19 PM HELOC Non Borrowing Owner Rescission
terpsfan Offline
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Joined: Feb 2007
Posts: 2,059
Our TIL account openings disclosures for HELOCs are built into the note. When there is a non-borrowing owner with rescission rights should we have the sign the note to show they got a copy of the material disclosures or is it sufficient that our acknowledgement for our rescission notice includes acknowledgment that they received a copy of Truth in Lending disclosures?

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Lending Compliance
#1651166 - 01/13/12 09:37 PM Re: HELOC Non Borrowing Owner Rescission terpsfan
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Where and how would they sign the note?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1651499 - 01/17/12 03:51 PM Re: HELOC Non Borrowing Owner Rescission terpsfan
terpsfan Offline
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Joined: Feb 2007
Posts: 2,059
Not sure I was just concerned that we did not have adequate proof of compliance since on closed end transactions they sign the TIL.

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#1651548 - 01/17/12 04:45 PM Re: HELOC Non Borrowing Owner Rescission terpsfan
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Signing an acknowledgment of receipt is a little different than "signing the note".
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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