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Mis-Classified Loan-no TIL

Home Forums Truth in Lending/ Regulation Z Mis-Classified Loan-no TIL

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  • #2492
    cbg7811
    Participant

    We have a loan on land only for consumer purpose. The loan officer did not give TIL disclosures. Giving the TIL, at this point
    does not fix the problem, but would you issue a TIL now using the current date? Or, just document the finding and know the loan is wrong?

    Thanks.

    #2787
    JGo9
    Participant

    You may not be able to correct the issue but you could produce the TIL with the date of when then loan was closed and that would at least show an effort to address the issue.

    #2788
    jholzknecht
    Keymaster

    The failure to provide a TIL disclosure may lead to reimbursement required by examiners or lawsuits from consumers.Providing the disclosure and making an adjustment cuts off the borrower’s right to sue and will eliminate examiner concerns since the adjustment has been made.

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