If a Rate Lock Extension Fee was incorrectly disclosed on a revised CD as Origination Points, can this be corrected with another revised CD before closing, or corrected on the final consummation CD?
Is the cost of an elevation certificate a valid change in circumstance? The elevation certificate is not a requirement of the bank but it is a requirement of the insurance company. If we don't need to re-issue the loan estimate where should the fee be disclosed on the closing disclosure?
Can Loan Estimate and Closing Disclosure timing run in conjunction with the seven-day waiting period for the LE? (Example - hand deliver the LE today, then hand deliver the CloD four days after delivery of the LE - then have the actual note signing four days
after delivery of CD) Agree or disagree?
Prior to Integrated Disclosures, a credit sale (selling and financing an OREO property) required us to disclose the Total Sale Price on an Estimated and Final TIL (12 CFR 1026.18(j)). Is there a similar requirement on the new Loan Estimate and/or Closing Disclosure or has this gone by the wayside?
In regards to TRID's services that a consumer is permitted to shop for, if the customer does not select a service provider and requests that the lender choose a service provider for them, is the amount charged subject to the 10% cumulative tolerance?
I have a question regarding tolerance categories once the TRID rules go into effect. Here is my potential scenario:
Our customer chooses to purchase Owner's Title Insurance. We do not require that they do this as a condition of the loan. What if the company they choose is an affiliate of our company. Would this fall into the no limit or zero tolerance category?
Regarding the Loan Estimate under Estimated Taxes, Insurance and Assessments: We were told that we had to estimate taxes, insurance including flood and other assessments In order to complete the monthly payment. How are we going to know if they are in a flood zone within 3 days of application with out running a determination? I would like to not incur that expense until we get back the intent to proceed.