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#1650468 - 01/12/12 09:10 PM Loan program change and cc
mac444 Offline
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Joined: May 2011
Posts: 77
This might have been addressed before..if the borrower requests change from a fixed rate loan to an adjustable rate loan, and the fixed rate had a rebate pricing (credit in block 2), but not the ARM product does not have rebate pricing, would this constitute a cc to revised the GFE credit in block 2 to Zero if done within the 3 days of borrower request?

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RESPA
#1650499 - 01/12/12 09:48 PM Re: Loan program change and cc mac444
RulesFollower Offline
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Joined: Oct 2011
Posts: 185
We issue new disclosures, with a new 10 day period, when there is a product change.

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#1650504 - 01/12/12 09:43 PM Re: Loan program change and cc mac444
mac444 Offline
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Joined: May 2011
Posts: 77
For the revised GFE can the fee in block 2 change? As of now I there is a tolerance violation as the credit went to zero.

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#1650514 - 01/12/12 10:19 PM Re: Loan program change and cc mac444
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Joined: Oct 2011
Posts: 185
It is a "new" application for credit asking for a "new" product that was previously un-disclosed...in essence, it is like a "new" GFE, not a correction of the 1st one. Of course, all of this needs to be clearly documented in your file. We utilize a "Product Change Form" that is used in conjunction with a "Changed Circumstance" form to clearly tell the story, including dates, when this happens. Our compliance officer was concerned that it might be a fair lending violation if the customer applied for a fixed rate loan but closed on an inhouse ARM, which is viewed as a loan with less favorable terms, without a very detailed explanation.

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