We have a loan that has closed. Citibank (investor) has suspended because the "your initial monthly payment is" on pg 1 is off by .01. The MI per month was estimated to be $35.98 and actually was $35.99 so the pmt was stated as $935.98 instead of $935.99. NO CHANGES WERE MADE to the loan-the rate, amount, the MI factor all were the same...it was caused by a difference in rounding (the MI company came to "35.9844444445. Our system rounded 35.984 to 35.98, they rounded the infinite number)

Prior to closing, the loan officer asked me about redisclosing, but since there was no valid circumstance and the fact that, to me, this fell into the "honest estimate", I told him not to.

IS there a circumstance to redisclose something like this? What is the point of redisclosing the GFE after the loan has settled?

There isn't. They are being jerks. They don't want to think or be logical, so they pass a rule that say "if it's not perfect (according to our procedures), we're not buying the loan." They don't have to deal with your upset and angry customer, you do. Sorry you have to deal with this. That's just plain stupid!

For future reference...IS there a valid circumstance to re-disclose this? My theory has always been that this is an ESTIMATE and when the ONLY change is a small (less than 1-2%) in the monthly payment when the MI was already included with the P&I...that there was no valid circumstance.

Should I be having the LO's re-disclose? Citi also has a requirement that the LO's email address must be on page one of the GFE...which is also NOT a requirment and hard to come up with a valid "circumstance" to re-disclose for this item only.

Rounding differences are not qualified changed circumstances.

As David stated these people are acting like jerks and I most definitely would be looking to change investors as soon as reasonably possible.

From Appendix C of RESPA.

Top of the Form —The loan originator must enter its name, business address, telephone number, and email address, if any, on the top of the form, along with the applicant's name, the address or location of the property for which financing is sought, and the date of the GFE.

A loan officer is not an it, the loan originator (the bank/lender) is.

From 1024.2

Loan originator means a lender or mortgage broker.

Problem is, it's their ball and their field so you have to play by their rules. First, check their selling guidelines to see if this is something that is spelled out or if the person reviewing your loan has made up their own rule. (it happens more often than not.) If it's in the guidelines, your only possible out would be to escalate this to the compliance area at Citi and convince them to let it go.

Bottom line: I agree with David. They're being jerks.

And I agree with Dan - find a new investor. Tell these guys to jump in a lake.

Unfortunately, that's rarely an option. Not to mention, Citi is a prominent player in the field.

In most of the situations like this that I've personal experience with, it turns out to be either a newbie or rogue reviewer who is imposing the suspense requirement. Going over their head to the compliance area and/or through your sales rep will likely get this item removed and the loan funded.

Remember to keep the contact info for the compliance area for the next time something off the wall comes up. Because I guarantee you it will.