Skip to content

When to Issue New PTIL (Refi/Home Improvement)

Answered by: 

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

First published on 04/02/2012

Filed under: 
Filed under compliance as: 

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics