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#1856427 - 09/27/13 03:59 PM $100 tolerance question
complyorelse Offline
Gold Star
Joined: Nov 2007
Posts: 442
U.S.
We disclosed a 5/1 ARM with 30 year amort; the rate is locked at disclosure. Our rates are based on the US Treasury. By the time the loan actually closed the Treasury had adjusted a bit which made the finance charge increase by $144. (No fees were left off or anything like that.) The APR remained well within tolerance. Should we have provided a revised TIL 3 days prior to closing because of the finance charge $144 difference?

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Lending Compliance
#1856456 - 09/27/13 04:27 PM Re: $100 tolerance question complyorelse
Truffle Royale Offline

10K Club
Joined: Jul 2003
Posts: 17,349
Dollar amount is not the determining factor for redisclosing an ETIL.
If the APR did not change by more than .125%, no redisclosure was required.
The final TIL given at the closing table would reflect the final numbers, including the $144.

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#1856471 - 09/27/13 04:36 PM Re: $100 tolerance question complyorelse
complyorelse Offline
Gold Star
Joined: Nov 2007
Posts: 442
U.S.
Thank you.

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