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I am so drawing a blank, are TIL disclosures required on a construction loan? We are only doing the construction loan.
Anyone that can expedite an answer would be greatly appreciated.Compliance amnesia – it happens to all of us:)
TILA does apply to construction-only loans and you do need to provide TIL disclosures. See Reg Z, 1026.17(c)(6) and Appendix D.
You are probably thinking of the RESPA disclosures that aren’t required for construction-only transactions. The new integrated disclosure rules, effective August 1, 2015, will apply to construction-only loans.
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