I'm going through the timeline and wondered if I'm missing something - need some guru help here:
LE mailed Thursday 8/6, states it is received Tuesday 8/11. If the disclosure is presumed received on 3rd business day (counting Saturdays), it should be received 8/10, right?? (See also Comment 19(f)(1)(ii)-2 that gives this exact scenario, stating it is received on Monday).
On 9/4, it gives as an example of a Changed Circumstance the receipt of an appraisal showing LTV >80% so now the loan needs MI. Is this based on eligibility -- because the consumer is no longer eligible for a non-MI loan-- or, because something relied on (a specific property value) became inaccurate? Either way, the fees would need to exceed tolerances to allow a revised LE, correct? I am assuming the fee in this case is upfront MI to a third party where the consumer is not allowed to shop - and not prepayment of future premiums or payment into escrow account (which would not be subject to tolerance). I don't often see this type of upfront MI but perhaps it is common?
For the post-consummation changes, if I start counting calendar days on 10/31, the 30th day would be Sunday, November 29. But the example gives Monday November30 as the last day to place corrected disclosures in the mail. Is this because the 30th day is a Sunday, so the can be sent on the next business day?
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