Posted by CopperheadVA on 9/11/08 1:31pm
Msg #263955
Reg Z Violation???
I received an overnight package today for my closing this evening. The borrower’s copy consisted of the HUD, First Payment Letter, Privacy Policy, and Amortization Schedule. There was a letter on top addressed to the borrowers that said they would receive a copy of all their loan docs via a CD within 60 days.
In the signing package, there were 6 copies of the RTC, but there were specific instructions for me to have borrower sign ALL docs and send ALL back to the TC. I was not to leave any docs from that package with the borrower. Wife is on title and listed on page 1 of DOT and in notary cert, but her name was not on the signature lines for DOT, TIL, or RTC.
I called SS. SS contacted TC and TC said I am to have wife sign DOT, TIL, and all copies of RTC. I am not to leave a copy of TIL or RTC’s with the borrowers. I questioned whether this was legal, with regard to Regulation Z – I specifically mentioned that the borrowers would not have any way to rescind the loan without this info (I know they can technically write a letter to cancel, but without the document, how do they know where to send it?). SS double checked and I was again told not to leave any copies with borrowers – all copies were to be signed and returned to TC. I have it in writing via e-mail.
I’m stunned.
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Reply by MW/VA on 9/11/08 2:27pm
Msg #263967
And I imagine the RTC has the usual language "acknowledge receipt of two copies of the RTC". What are they thinking? We follow instructions to a point, but don't participate in anything illegal either. Arguments with clueless ss or tc are pointless. It sounds like someone is reading some instructions & taking them too literally. I know I'd make the copies of the RTC for them. Also, if they don't get their copy via CD for 60 days, what do they have to review during the recission period? There are some strange things going on in this crazy market.
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