Forgetting a Fee on the Loan Estimate

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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