Question:
What happens when you forget a fee on the Loan Estimate and it’s added to the Closing Disclosure, but it is in an Unlimited Tolerance Category?
Answer:
If you miss disclosing the fee on the Loan Estimate, you will be in violation of the good faith standard. The Commentary to §1026.19(e)(3)(iii) #3 states that this type of error would move the fee to zero tolerance.
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Published
2019/10/03
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Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar, or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups, and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru.
Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports related!