July 22, 2013 at 10:15 am EDT
#3672
rcooper
Member
Since this post I have come across information (preamble from HPML final rules) that indicates that early disclosures are now being considered material disclosures and should be given to non-borrowers who have the right to cancel. Going forward, I recommend giving the early TIL, as well as the final TIL, to all individuals with the right to cancel.