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Final TIL w/New Index Not In Tolerance of Initial

Answered by: 
BOL Guru

Question: 
A borrower receives a GFE and TIL within 3 days - it's a 5 year ARM with a floor of 3. Initial TIL based on index at time. Final TIL is updated with new index and is not within tolerance of initial. Do we need to redisclose and wait 3 days before closing?
Answer: 

If a change causes the APR on the ETIL to be out of tolerance then you must redisclose the ETIL. Redisclosing face to face will result in a 3 business day wait and mailing the redisclosure will result in a 6 business day wait. You can find additional information by reviewing 1026.19(a) and its Commentary.

First published on BankersOnline.com 1/28/13

First published on 01/28/2013

Filed under: 
Lending
Filed under lending as: 
ARM

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