Signed TIL Missing from Credit File

Question:

We have a non-RESPA Auto Loan under 25,000.00. The credit file is missing the signed final TIL. Is this a Reg Z violation and should we redisclose?

Answer:

Having a signed & dated TIL disclosure (12 CFR 226.17(a)(1) footnote 37) is the easiest way to prove that you complied with the TILA requirement to provide the document prior to consummation (12 CFR 226.17(b)) but it is not required.

First published on BankersOnline.com 3/12/07