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New TIL Required for Change In Circumstance?

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Question: 
Is a new truth in-lending required when there is a change in circumstances? (2nd lien)
Answer: 

A new truth in lending would only be required if the change in circumstances resulted in a new APR that is outside of the tolerance for the previously provided TIL disclosure. Lenders often tie both the new GFE and new early TIL together, but as Carl Pry pointed out in a recent ABA Bank Compliance Magazine article, the two don't need to be linked and often providing too many disclosures can be confusing and burdensome for the consumer.

First published on 05/19/2014

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