Re: Redisclosing TIL


I am a little confused by your question, but since I have been spending so much time with 1,400 pages of proposed Regulation Z I am getting confused about everything.

If appears you want to avoid having a first lien higher-priced mortgage, which occurs when your APR exceeds the APOR by 1.5 or more percentage points. In your situation you could assure the APR stays below the threshold either by lowering the origination charge or lowering your rate. If you lower the APR, by either method, you would need to re-disclose if the APR changes by more than the allowed tolerance. It is doubtful that you would have a tolerance problem. But, if you do need to redisclose, you must delay closing until three business days after the consumer receives the revised disclosure.