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#1641074 - 12/20/11 05:05 PM GFE Reissue
Mainiac Offline
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Joined: Nov 2005
Posts: 147
If we neglected to include a monthly PMI premium in the disclosure on page 1 of a GFE in the "Summary of your loan" payment box, can we reissue a GFE more than 3 days after we knew of the monthly premium if there are no changes in any of the fees on Page 2?

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RESPA
#1641175 - 12/20/11 06:53 PM Re: GFE Reissue Mainiac
RulesFollower Offline
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Joined: Oct 2011
Posts: 185
No, can't redisclose to correct your own error.

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#1641299 - 12/20/11 08:43 PM Re: GFE Reissue Mainiac
Mainiac Offline
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Joined: Nov 2005
Posts: 147
But there are no changes to the fees disclosed on page 2 of the GFE, only on the total payment that includes the monthly pmi. There would be no changes in the page 2 fees and no tolerance violations on the HUD-1.

Are you saying the bank needs to eat the monthly PMI?

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#1641797 - 12/21/11 05:11 PM Re: GFE Reissue Mainiac
Avanti Offline
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Joined: Feb 2010
Posts: 139
Originally Posted By: Mainiac

Are you saying the bank needs to eat the monthly PMI?


I do not believe that the section you are referring to is subject to a tolerance. If the PMI payment was quoted and was wrong, not simply ommitted, The Bank would not eat the difference.

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#1642162 - 12/22/11 01:43 PM Re: GFE Reissue Mainiac
WHEDA Offline
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WHEDA
Joined: Apr 2009
Posts: 189
Wisconsin
What if the LTV was 95% but only the P&I payment was disclosed on page 1; i.e., the monthly MI premium was totally omitted? Would the lender be responsible for covering the cost of MI until it was eligible to be discontinued?

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#1642216 - 12/22/11 02:31 PM Re: GFE Reissue Mainiac
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
You would not be responsible for the monthly premiums. However, if you collect any premiums up front and they were not disclosed in Block 3 you would have to cure any tolerance violation caused by not disclosing the up front premiums.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1642504 - 12/22/11 07:03 PM Re: GFE Reissue Mainiac
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
I have a question regarding redisclosure of the GFE. We have a change circumstance for a borrower requested lower loan amount. I know we can only change the loan amount but I am looking and the initial deposit into escrow (block 9) is different on the revised. This can't change correct?

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#1642507 - 12/22/11 07:09 PM Re: GFE Reissue Mainiac
RulesFollower Offline
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Joined: Oct 2011
Posts: 185
You are not required by RESPA to redisclose for a lower loan amount but if you do, the initial deposit into escrow can fluctuate as it is not a tolerance item.

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