When it comes to TRID loans, we are often asked, “Do I need to re-disclose the Loan Estimate?” While you ARE required to re-disclose any time you’ve locked a rate (with a written agreement), that’s it. There is no other time or scenario where you would be required to re-disclose a Loan Estimate. There may be some situations that arise where you would want to re-disclose but these are really for your own benefit, specifically, so you can reset tolerances.
Let’s say the borrower requests more money; or the appraiser indicates an additional inspection is needed; or the applicant doesn’t express intent to proceed until after the initial Loan Estimate has expired. Each of these circumstances allow, but do not require, you to re-disclose your Loan Estimate.
To determine whether you should re-disclose, look at what impact the change will have on your fees. If you have a fee change that throws you out of tolerance, you will likely want to re-disclose, as a means to avoid a tolerance cure at closing.
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!