Is a TIL Disclosure Required?

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Question:

Are we required to give a TIL disclosure on a 9 month interest-only draw down credit line for new construction with no committed end financing (we do disclose at time of application). The loan is a 9 month interest-only payment and matures without a PandI payment made. There is no final closing; the loan is paid off by another lender.

Answer:

Yes, assuming you are lending to a consumer. See Appendix D of Regulation Z for disclosure calculation models. Many other commercially-produced solutions are also available.

First published on BankersOnline.com 1/7/02