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Reg on Early TIL and Treasury Index Figure

Answered by: 
Dan Persfull

Question: 
Below is a question answered by a BOL Guru. <strong>Question: </strong>When we disclose an early TIL for an adjustable rate mortgage, we use the most recent available corresponding Treasury index figure when calculating the second payment stream for the APR. If the loan closes weeks later, should we then use the most recent index figure even if it differs from the early TIL?
Answer: 

I am assuming you are providing a final TIL. The final TIL should reflect the index value and discount/premium you used at closing. The index value could be the then current value (which is the one I suggest you use) or it can be a value within your stated look-back period.

Can you cite the Reg that supports this.

Answer: Regulation Z - 1026.18(s)(2) and its Commentary.

First published on 12/02/2013

Filed under: 
Compliance
Filed under compliance as: 
Reg. Z

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