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).
