What exactly is an “extraordinary” or “other unexpected event” under the TILA-RESPA integrated disclosure rules? The new definition of “changed circumstance” includes one prong defining the situation as “an extraordinary event beyond the control of any interested party or other unexpected event specific to the consumer or transaction.” General rules noting specific triggers of a changed circumstance will be almost impossible to define in advance — and will likely need to be defined on a case-by-case basis. General determinations will be few and far between.
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Ari Karen is an experienced litigator and speaker who has focused his practice in representing financial institutions in both government investigations and litigation before state and federal trial and appellate courts nationwide. Mr. Karen’s practice is diverse, representing clients on matters concerning banking regulations, Dodd Frank financial reform laws, contractual disputes, employment and labor statutes, wage-hour class actions, employment discrimination and fair lending matters, whistleblower complaints and non-competition claims, among others.
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