[timob1973]

I’m looking at several TILs and I’ve noticed that the Total Sale Price on the TIL Fed box is being completed even though the transactions are not credit sales by the Bank. Is this a violation of Regulation Z? If so, can you please provide a site where it states that completing the 5th TIL box is a violation if the transaction is not a credit sale by the lender? Your help is greatly appreciated.

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[rcooper]

You are required to include the total sales price for credit sales (1026.18(j)). Although I would generally not advise including this disclosure when it isn’t required, I don’t believe it would be a violation to include it because of the language in 1026.18-1 where it says disclosures under this section “need” only be made as applicable; it does not say “should”, “must”, or “may” which leaves some room for disclosing when not required. However, since this is not required for non-credit sale transactions your auditor/examiners may interpret the inclusion of this as a misunderstanding of the regulation, cite it as a violation and see it an indicator that there may be broader issues with your disclosures. I would recommend only including this as required – document the issue, make adjustments to correct the process, train, etc. and you should be fine.

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