I'm looking at our banks Truth in Lending Disclosure and it appears to be missing the number of payments and the date the first payment is due. It does state that payment should be remitted monthly and and the amount of each monthly payment. This is a fixed rate, closed-end mortgage loan.

I faintly remember some changes that were being made to the payment stream, but when I read 1026.18 and look at the model form it still appears to include the before mentioned information that is currently omitted.

Is the first payment date and number of payments required to be disclosed on the TIL? Thanks in advance.

This is a fixed rate, closed-end mortgage loan.

You need review 1026.18(s) and its Commentary.

Thank you Dan. Our model form is a match to H-4(E-F). We do not have any of the other risky loan features described in 1026.18(s). Thank you for your help.

Keep in mind that this is a summary of the actual payment schedule. Even when a loan is covered by 18(s) and you are in compliance with that section, you still need to know all the information required by 18(g). Without the fully-expanded payment schedule, you cannot verify the Total of Payments, Finance Charge, and APR. Although the full schedule may not be disclosable when 18(s) applies, failure to retain it constitutes a violation of Section 1026.25--which requires "evidence of compliance" with all parts of Regulation Z that apply to each closed-end loan.