TIL Disclosure Requirements

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Question:

We have always made it a practice to give an initial TIL on our home-equity closed end loans, no matter the purpose of the loan. Some of our offices state that they have never given an initial TIL only the final at loan closing. Can you tell me the specifics of when an initial TIL must be given on closed-end home-equity loans? I believe we have chosen always to over disclose and give the initial disclosure, instead trying to have our lenders remember when it is required and when it is not.

Answer:

The only time you must give a Preliminary TIL disclosure is purchase/construction of primary dwelling that is also subject to RESPA. Therefore, refinancings, home equity, 2nd liens, etc. do not need a P-TIL. See Section 226.19(a) of TIL for more info.

First published on BankersOnline.com 09/2/02