When to Issue New PTIL (Refi/Home Improvement)

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Question:

We disclosed a PTIL to refinance a borrowers home and add home improvement funds. At the closing, they decided not to improve reducing amount. Must we issue a new PTIL?

Answer:

Not necessarily. It depends on the APR disclosed. If they are still accurate, then no new P-TIL disclosure is needed. If the APR went up, then you need to redisclose.

You should refer to 1026.19(a) for more information. Also, the Philadelphia FRB had a great article on the accuracy issue. You can find it here.

First published on BankersOnline.com 4/2/12