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A mortgage operations checklist raises a question about TILA right of rescission. Which action should the branch supervisor recommend?

Correct Answer

A) Give each consumer with an ownership interest rescission rights

Why this is correct: The Truth in Lending Act (TILA) provides a right of rescission (cancellation) for certain loans secured by the consumer's principal dwelling. A fundamental rule is that this right must be given to each consumer who has an ownership interest in the property being used as security. The correct action, "Give each consumer with an ownership interest rescission rights," directly applies this rule. Why the other choices are wrong: "Use an internal exception instead of the required federal disclosure or timing rule" is wrong because TILA rescission rights are a federal consumer protection that cannot be waived by internal policy. "Wait until a regulator asks for the file before applying the federal requirement" is wrong because the right must be given at closing, as required by law. "Treat the TILA Right of Rescission review as complete because the file contains a related SAFE Act testing note" is wrong because SAFE Act licensing requirements are separate from TILA disclosure and rescission rules; one does not substitute for the other. Exam tip: For TILA rescission, remember it applies to principal dwelling security interests, and the right must be given to all owners. Never substitute a different compliance item for this specific right.

Answer Options
A
Give each consumer with an ownership interest rescission rights
B
Use an internal exception instead of the required federal disclosure or timing rule.
C
Wait until a regulator asks for the file before applying the federal requirement.
D
Treat the TILA Right of Rescission review as complete because the file contains a related SAFE Act testing note.

Why This Is the Correct Answer

The correct response is "Give each consumer with an ownership interest rescission rights" because TILA rescission rights protect consumers with ownership interests in a principal dwelling.

Why the Other Options Are Wrong

Option B: Use an internal exception instead of the required federal disclosure or timing rule.

Use an internal exception instead of the required federal disclosure or timing rule. is not correct because it does not apply the rule tested by this file scenario.

Option C: Wait until a regulator asks for the file before applying the federal requirement.

Wait until a regulator asks for the file before applying the federal requirement. is not correct because it does not apply the rule tested by this file scenario.

Option D: Treat the TILA Right of Rescission review as complete because the file contains a related SAFE Act testing note.

This distractor shifts the issue to a different trigger, product, or timing rule instead of applying the rule tested in the stem.

Memory Technique

TILA right of rescission: identify the rule being tested, then choose the action that documents or applies that rule before the file moves forward.

Exam Tip

Match the file facts to TILA right of rescission; do not choose an exception or shortcut that skips the required rule.

Common Mistakes to Avoid

  • -Choosing an internal exception instead of the governing rule
  • -Treating preliminary or informal facts as a substitute for required documentation
  • -Answering from a familiar but unrelated mortgage topic
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