Posted By: Kelsey D
TIL Redisclosed When Not Required - Wait 3 Days? - 04/02/12 03:02 PM
Our vendor packages the GFE and TIL together when redisclosing, even if only one is required. Am I correct in thinking that we don't have to comply with the MDIA waiting period to close the loan even though a new TIL was delivered? The APR was within tolerance and redisclosure of the TIL was not required. I'm basing my opinion on this (see quote below), but I've found conflicting opinions in prior threads.
"It is important to note that the three-business-day waiting period for corrected TILA disclosures applies only if the changes occurred as a result of an APR error. Otherwise, only the corrected disclosure is required, and lenders do not have to wait three business days before consummation."
"It is important to note that the three-business-day waiting period for corrected TILA disclosures applies only if the changes occurred as a result of an APR error. Otherwise, only the corrected disclosure is required, and lenders do not have to wait three business days before consummation."