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TIL Disclosure for Construction Loan

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  • May 21, 2015 at 1:37 pm EDT #6928
    Anonymous
    Inactive

    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.

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  • May 22, 2015 at 10:01 am EDT #6930
    rcooper
    Member

    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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