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I’m confused on how to comply with this. “Some overdrafts are rewritten as loan obligations in accordance with an institution’s loan policy and supported by a documented assessment of that consumer’s ability to repay”. We currently use TIL forms from our 3rd party vendor for repayment plans, but the payments are only 4 in total and no interest is charged. Also no underwriting is done or provided for in our Loan Policy. We just received an audit and the underwriting and ability to repay was an item noted. Do we have to use the TIL forms since we do not meet the TIL requirements? What is the best way for us to handled this?
Thanks
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