HELP FAST - Please

Posted By: upstateNY

HELP FAST - Please - 01/19/11 07:21 PM

We are still trying to get our new TIL's ready for 01/30. The most recent version sent to us by our vendor DOES NOT include a place for the borrowers to sign the TIL. I've been in banking a very long time and have always seen a signature on a TIL.

I'm on a webex right now and can't research. The vendor needs to know today if we will require the borrowers to sign our TIL's, requiring additional programming. Please, does anyone know quickly whether sigs are required under Z on the TILS?
Posted By: MN Banker

Re: HELP FAST - Please - 01/19/11 07:46 PM

Signatures are not required by regulation on the TIL
Posted By: RR Joker

Re: HELP FAST - Please - 01/19/11 07:49 PM

Technically, no...but most FI's want a signature because of the legality of the document.
Posted By: VRV

Re: HELP FAST - Please - 01/19/11 07:53 PM

Reg. Z does not require that the disclosure be signed. However, most lenders have a policy that the customer sign the disclosure as a way of proving that the customer received it.
Posted By: upstateNY

Re: HELP FAST - Please - 01/19/11 07:59 PM

Originally Posted By: RR joker
Technically, no...but most FI's want a signature because of the legality of the document.


Thanks, do you feel that we place ourselves at risk by not having them signed? I've never seen a TIL without a sig line..and I've been in banking for many years.

I don't like to ask for sigs if not required, as it's one more item that can be picked up as an audit exception. But this seems alien to me.
Posted By: Kathleen O. Blanchard

Re: HELP FAST - Please - 01/19/11 08:00 PM

Many banks do NOT require a signature line. It is up to the bank.
Posted By: QCL

Re: HELP FAST - Please - 01/19/11 10:52 PM

Originally Posted By: RR joker
Technically, no...but most FI's want a signature because of the legality of the document.


We do as a matter of bank policy.
And we would go back to the vendor and ask for it.