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New Reg Z Rules - Matured Loan

Answered by: 
Dan Persfull

Question: 
Do I need to supply an early TIL and follow the new Reg Z rules for a matured loan? If so, when should the early TIL be dated and when should the renewal loan documents be dated? Waiting the seven days will push the customer into past-due status.
Answer: 

Consumer loan requests dated on or after 7/30/09 are subject to the new timing requirements. The application date will be the date you received the request to refinance the loan and your timing requirements start from that date. If the loan officer did not work his maturing loan report to get the loans refinanced by the maturity date, they will just have to carry the loan past due until the timing requirements are met.

First published on BankersOnline.com 11/02/09

First published on 11/02/2009

Filed under: 
Compliance
Filed under compliance as: 
Loans
Renewal

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