Compliance – Change of Circumstance – Fees Disclosure: What are the timing requirements if a CD has been issued and a valid change of circumstance occurs? In our case a POA was added, which resulted in an increase of recording fees.

Answer: It can be disclosed on the CD even if the initial CD has gone out. The fee can be increased as long as it is re-disclosed no later than 3 days after finding out about the POA. Your example does not reset the 3-day clock for closing. The APR is not increasing more than [...]

2019-02-21T16:13:23-05:00February 25th, 2019|

Compliance – TRID: If we mistakenly provided the wrong mortgage insurance amount in the projected payments section of the Loan Estimate, how is this corrected?

Answer: Most investors care about the CD. The projected payments does carry statutory damages; however informal guidance from the Bureau provided that most items can be corrected via the CD. In this case, unless FHA or USDA, there are multiple factors that can influence the cost of the MI beyond the 6 points of data. [...]

2018-05-29T16:52:23-05:00April 24th, 2018|