Answer:
The TIL disclosure requirements and calculating the ability to repay are governed under two separate sections of Regulation Z and are not related.
First published on BankersOnline.com 10/31/11
Variable Rate Real Estate Loans-Debt/Income Ratio
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Question:
Our software company recently changed the TL Statement on HPML Real Estate Loans to disclose a maximum payment amount on Variable Rate Real Estate Loans (maximum during first five years). We understood that the Debt to Income Ratio on these Loans were to be based upon the maximum during the first 7 years after consummation. Please Help.
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