Could anyone point to guidance on what the resolution is or regulatory requirements are for failing to provide a CD to the borrower 3 days prior to consummation. Our closing manager just advised that they "missed one". My first thoughts were to provide, wait 3 days open rescission again but haven't been able to find clear direction in the regulations.

Thanks

I don't think you can unring this bell. It's a violation, period, And you can't cure it. I assume that the CloD was given at closing, so rescission dates won't be a problem. The violation would only be the timing of the CloD.

If you didn't provide any CloD at all, you've got a much bigger violation on your hands.

Thanks John. It was provided at closing and they did execute the ROR forms. Our concerns now lie in figuring out the salability in the secondary marketplace.

Investors have refused to purchase loans for a lot less significant things.

My experience has been that most investors will not purchase a loan with this type of error. There are some companies out there that say they will purchase files with TRID errors- the pricing won't be as good and they may have different criteria on what they will and won't purchase.