New Timing of TIL

Question:

Am I correct in stating that the TIL must now be given early and there is not an additional one required unless APR becomes inaccurate?

Answer:

The July 30, 2009 changes to Reg. Z now require an early TIL for all RESPA covered applications secured by a consumer's dwelling, including vacation and secondary homes. A final TIL is not required unless the early TIL becomes inaccurate. Previously, an early TIL was required only for applications to purchase, acquire, or the permanent financing of the initial construction of, and secured by, the consumer's principal residence.

First published on BankersOnline.com 10/12/09