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#2046782 - 10/28/15 08:21 PM Re-disclose LE for change in APR?
Ninky Offline
Gold Star
Ninky
Joined: Nov 2002
Posts: 357

Are we required to re-disclose the LE if the APR changes under the old tolerance limits? i.e. we add auto debit during the processing of the loan, the APR drops .25% because they get the lower ate for auto debit. Do we re-disclose the LE under TRID
like we had to re-disclose the TIL before? Or do we only have to re-disclose when the fee tolerances are breached or there is a change in circumstance?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2046799 - 10/28/15 08:40 PM Re: Re-disclose LE for change in APR? Ninky
Kat Offline
Junior Member
Joined: Apr 2014
Posts: 41
Montana
Hi Ninky,

The way I understand it, as long as you are not dealing with a rate lock, a rate change does not trigger a revised LE even if it makes the APR inaccurate. You would just reflect the accurate rate with the corresponding APR on the CD that you are delivering 3 days prior to consummation anyway. If, however, you have a rate lock agreement with the lower rate, than you would need to issue a revised LE within 3 days of the new lock agreement.

Hope this helps. smile

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