Do We Need a New LE?

When it comes to TRID loans, we are often asked, “Do I need to re-disclose the Loan Estimate?”  While you ARE BSA Training and Banking Regulations Compliance Consulting diane11 - Do We Need a New LE?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.

Published
2017/04/13
Diane Dean

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