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#1407313 - 06/23/10 07:38 PM Redisclosing GFE prior to closing
deh Offline
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Joined: Mar 2006
Posts: 866
We have a scenario where the we need to extend the rate for just a few days prior to closing due to some delay that caused us to go beyond the existing lock. Do we give the revised GFE at the closing table? Seems silly, nothing is changing just extending the rate a few days. I suppose we have to document the revision......

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#1407468 - 06/24/10 02:22 AM Re: Redisclosing GFE prior to closing deh
Truffle Royale Offline

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I wrestle with this one because I'm afraid an examiner would argue this is a rate lock which is the only changed circumstance that requires a redisclosure. So, to be safe, I'd redisclose. If there's no extension fee your APR couldn't change necessitating the 3+3 wait period, so yes, you could give a redisclosed GFE at the closing table.

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#1407473 - 06/24/10 11:33 AM Re: Redisclosing GFE prior to closing Truffle Royale
OldSchoolBanker Offline
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FL
I am curious - are you redisclosing only to reflect the lock expiration and extension? No loan amount change, no fee changes other valid change circumstances?

I am not sure I understand why a redisclosure would be applicable for the lock extension (assuming no fee changes).
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#1407481 - 06/24/10 12:22 PM Re: Redisclosing GFE prior to closing OldSchoolBanker
Truffle Royale Offline

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Because the dates on page 1 change. A rate lock could do exactly the same thing that's why I'm not sure.

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#1407530 - 06/24/10 02:13 PM Re: Redisclosing GFE prior to closing Truffle Royale
deh Offline
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Joined: Mar 2006
Posts: 866
Yes you are correct. There are no fee changes only dates will change.

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#1407740 - 06/24/10 05:39 PM Re: Redisclosing GFE prior to closing deh
West Coast Comp Offline
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Lost in the rain.
Redisclosure is not required just because the GFE has expired. You can always honor the terms of the original GFE. But you certainly don't have to since the GFE has expired. The point of the dates on the front is to establish the "minimum" time that the GFE is good for. If you are not issueing a new formal "rate lock", there would be no need. If you are giving a new formal rate lock then give the disclosure.
If you are going to give a new disclosure make sure it is within 3 days of the change event.
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#1407992 - 06/24/10 09:10 PM Re: Redisclosing GFE prior to closing West Coast Comp
Truffle Royale Offline

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the GFE isn't expiring necessarily expiring. The rate lock is. If, like me you think examiners may look at that as a relock of the rate, I say redislose. Better be safe than sorry.

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