Posted By: FSLICBanker
RoR and proof of separate CloD's to borrowers - 08/02/22 06:45 PM
The Commentary to 1026.17(d) refers to situations where there are multiple parties (e.g. husband and wife) as borrowers on a TRID loan subject to rescission. The Commentary states that final disclosures, aka CloD, "must be given separately to each consumer who has a right to rescind".
Should the situation ever arise, I'm trying to determine how best to convince an auditor or examiner that both the husband and the wife received separate copies of the CloD We normally receive one copy back from the closing attorney with both signatures in the Confirm Receipt section with no documentation in file to show that each rescindable borrower in fact received their own CloD.
My thanks in advance.
Should the situation ever arise, I'm trying to determine how best to convince an auditor or examiner that both the husband and the wife received separate copies of the CloD We normally receive one copy back from the closing attorney with both signatures in the Confirm Receipt section with no documentation in file to show that each rescindable borrower in fact received their own CloD.
My thanks in advance.