| Re: Truth-in-Lending Disclosure Failure Leads to Mortgage Becoming "Unsecured"
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The first TIL is an estimate only, after they application is taken the TIL that is issued with the application is not replaced until closing, at closing you get the final TIL for the actual program and product that you are closing to. The lender is not required to issue interim TIL's. There is no violation if there is no interim TIL issued. There must be an initial TIL and a Final TIL.
No it is not a violation of TIL to use Stated Income regardless of the way the income is derived...income and documentation does not fall under RESPA, Reg Z or Truth in Lending Regulations.
Without a qualified forensic review of the documents it would be impossible to determine if the Lender had violated RESPA or Reg Z which are the regulations surrounding Truth In Lending. |