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#1654657 - 01/23/12 09:15 PM RESPA- Change Circumstances
audit23 Offline
New Poster
Joined: Feb 2011
Posts: 13
Blocks subject to the tolerance buckets on the GFE cannot increase unless related to change circumstances. The lowering of fees is allowed regardless. If changed circumstances are going to create tolerance issues for those charges, the affected blocks can be revised. This is simple for the 0% and 10% tolerance buckets.

What about fees which can change by any amount; are those allowed to be changed by any amount without being tied directly to change in circumstance?

In the case of escrow, there is no tolerance; therefore, no changed circumstance is required. If we are redisclosing as a result of another changed circumstance and we have revised the escrow deposits based on information not relied on at the time the initial GFE was issued, there is no harm in disclosing the more accurate figures and in fact, provides the borrower a more accurate disclosure of actual cash to close.


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#1654686 - 01/23/12 10:20 PM Re: RESPA- Change Circumstances audit23
RulesFollower Offline
100 Club
Joined: Oct 2011
Posts: 185
You are correct. It has been determined by the powers that be that areas with no tolerances assigned, initial escrow deposit for example, can change to more accurate figures during the re-disclosure process.

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