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New TIL Disclosures Required 3 Business Days?

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Are new TIL disclosures required 3 business days prior to closing the transaction if the interest rate and associated APR go DOWN by more than 1/8 of 1%. For instance 4.50% was disclosed initially, but rates dropped and now rate is at 4.00%?

This will depend on your regulator. The FDIC has taken the stance that if the APR is out of tolerance either up or down then a revised ETIL must be issued. This is also from the Philadelphia Fed.

First published on 11/17/2014

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