Answer:
Answer by David Dickinson: Not a final TIL (or preliminary TIL disclosure), but if it is the grantor's primary dwelling, they should get a Right of Rescission.
Answer:
Answer by Dan Persfull: If the dwelling is the grantor's primary residence then they are a consumer for the purposes of rescission and they must receive the right to cancel and copies of the material disclosures. The TILs would be part of the material disclosures.See Reg. Z, Section 1026.23(a)(3)(ii).
Answer:
Answer by David Dickinson: I agree with Dan. The material disclosures would not have the grantor's names on them (not prepared for them), but they should receive a copy so they are properly informed of the risk they are entering by allowing their primary dwelling to be used as collateral.
First published on BankersOnline.com 1/9/12; citation updated 12/24/12
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