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#2044188 - 10/14/15 05:16 PM Curative Action Questions
WHEDA Offline
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WHEDA
Joined: Apr 2009
Posts: 189
Wisconsin
What is the Curative Action if the 5-year calculations in the Comparison Section of page 3 of the LE are incorrect?


Also, what is the Curative Action if the APR is incorrect by more than .125%?


Thank you.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2044233 - 10/14/15 06:41 PM Re: Curative Action Questions WHEDA
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,631
Galveston, TX
Any error on an LE is a violation. There is no cure.

APR issues remain the same as now. An APR violation on a closing disclosure is a reimbursable offense.
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#2044340 - 10/15/15 01:12 PM Re: Curative Action Questions WHEDA
WHEDA Offline
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WHEDA
Joined: Apr 2009
Posts: 189
Wisconsin
Thanks Randy.

I am with a state HFA that purchases loans originated by front-line lenders. In your opinion, is an error in the 5-year calculations, or any other violation with no cure, something that should prevent an investor from purchasing the loan, or is it more something the originating lender would need to address if their reg agency auditors were to discover it?

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#2044361 - 10/15/15 01:54 PM Re: Curative Action Questions WHEDA
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,631
Galveston, TX
This should be a discussion that you have with your legal counsel.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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