It’s normal for changes to occur during the loan process. If the loan is subject to TRID, however, you have to be careful. Knowing whether you have a valid changed circumstance is very important and it dictates whether you can reset tolerances. Are you handling changed circumstances correctly?
Below are a few questions we’ve received related to changed circumstances:
Question: If we switch from a third-party appraisal in Section B to an internal evaluation fee in Section A that will ultimately cost less, do we need to re-disclose?
Answer: Assuming the change is being made due to new or changed information (i.e. a valid changed circumstance), you will want to re-disclose the change in services within three business days, even though the cost is ultimately being reduced. Otherwise, you take the risk that someone will see the new service in Section A as though you’re adding a service, even though it’s replacing the appraisal that was disclosed in Section B.
Question: Can we change or even lock a rate after delivering a Closing Disclosure and if so, would we need to re-disclose?
Answer: There’s nothing that prohibits the rate from changing after a Closing Disclosure has been delivered and nothing that prohibits you from locking a rate after the Closing Disclosure has been provided. Remember, though, you could trigger a new three-day waiting period. A revised Disclosure would be required if anything on the prior Disclosure became inaccurate.
Do you have more questions? If so, be sure to JOIN US for our webinar, “TRID: Changed Circumstances & Revised Disclosures”.
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!