If we are re-working a loan, and we decide to give a lower APR (and we forego any fees) do we have to send the customer a new TIL? Our lenders seem to think that as long as no fees are involved, and since we are benefiting the customer, that a new TIL disclosure is not necessary.
We have been experiencing some losses when we repo vehicles because of the high mileage on them. When we are looking at approving a loan applicaton secured by a vehicle, can we take into consideration the amount of miles the customer would put on the vehicle in a year by looking at their home address compared to their work address? And if high, require more of a down payment or less amortization period?