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#1346731 - 02/20/10 08:20 PM GFE
gunches Offline
100 Club
Joined: Dec 2005
Posts: 210
We received an application on 2/10 and prepared early disclosures. Customer called yesterday and wants to decrease loan amount by $12,000 - do we need to do a new GFE, and if so when does the time line start. As of 2/10/10 or as of 2/19/10??

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Lending Compliance
#1346734 - 02/20/10 10:48 PM Re: GFE gunches
Truffle Royale Offline

10K Club
Joined: Jul 2003
Posts: 17,341
What time start are you talking about? You're still offering the same rate, just changing the loan amount. You do a new GFE to change the amount and any other charges based on the loan amount. If that changes the APR, then you have to deal with MDIA and the three days there. Is that the time you meant?

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#1346803 - 02/22/10 01:40 PM Re: GFE Truffle Royale
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,710
Bloomington, IN
Quote:
do we need to do a new GFE, and if so when does the time line start. As of 2/10/10 or as of 2/19/10??


A customer requested change is a qualified changed circumstance, if you choose to issue a revised GFE you must do so within 3 business days of learning of the changed circumstance, in this case 2/19/10 would be your start date.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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