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Should the “payment schedule” be included on a TIL disclosure for a closed-end loan secured by real property or dwelling?
Yes, the TIL disclosure should always include the payment schedule disclosure. The content of the payment schedule for mortgage disclosures changed on January 31, 2011. Previously all loans received a payment schedule disclosure as required by section 1026.18(g). As of January 31, 2011 the 18(g) disclosure is for loans that are not secured by real property or a dwelling and for loans secured by real property or a dwelling the onsumer receives a new disclosure required by section 1026.18(s).
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