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.
David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.