TIL Disclosure Tolerance For Errors?

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Question:

On the TruthInLending Disclosure that is signed at closing on a mortgage, is there a tolerance amount that is acceptable in case of any computing errors? If any errors are found, should a new TIL be signed?

Answer:

This is such an important issue a cursory reply would be insufficient, and a sufficient answer could depend on many factors and be lengthy. Instead I would refer you to some handy resources from the ABA Compliance Magazine. (You can get reprints if you do not have them handy and the price is down by 50% I believe.) These are starting points.

Curing Truth in Lending Violations, D. Edwin Schmelzer and Walter E. Zalenski, January/Winter 1989, p. 13.

Restitution Redux: The TILA Reimbursement Rules After the Rodash Amendments, Mar/Apr 1998, p. 7.

Revisions to Truth in Lending: Congress Cures the Rodash Problems, D. Edwin Schmelzer and Walter E. Zalenski, January/February 1996, p. 3.

Truth in Lending Adjustment Calculations: TwoError Variety, Alan J. Dombrow, July/August 2001, p. 3

Truth in Lending Error Resolution Procedures, Robert P. Chamness, January/Winter 1990, p. 42.

Truth in Lending Error Resolution Procedures, Robert P. Chamness and Alan J. Dombrow, Jan/Feb 2000, p. 25.

First published on BankersOnline.com 8/4/03