We have a loan on land only for consumer purpose. The loan officer did not give TIL disclosures. Giving the TIL, at this point
does not fix the problem, but would you issue a TIL now using the current date? Or, just document the finding and know the loan is wrong?
The failure to provide a TIL disclosure may lead to reimbursement required by examiners or lawsuits from consumers.Providing the disclosure and making an adjustment cuts off the borrower’s right to sue and will eliminate examiner concerns since the adjustment has been made.