As we have previously reported in our November 2010 newsletter, December 23, 2010 and January 15, 2011 blogs, changes to the Truth in Lending disclosure form are effective for applications taken on or after January 30, 2011. As you may recall, the rule substitutes the interest rate and payment summary tables for the existing payment schedule on applicable loans.
As loan platforms are being updated, we’ve been getting the following question: Can we provide a Preliminary TIL disclosure under the “old” format prior to January 30th, but give a Final TIL under the “new” format after January 30th? The answer is “yes”. Truth in Lending does not require that the format be consistent between the Preliminary and Final TIL disclosures.
Technically, you can still give the “old” Final TIL disclosure for applications received prior to January 30th, but your system may not produce it anymore. That’s what has caused all the questions this week.
Let us know if we can be of help. We are only a phone call/email away.