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#2076184 - 04/28/16 05:27 PM Changed Circumstance - cash fees vs. financed
Feather Offline
Member
Joined: Nov 2010
Posts: 61
Do we have to redisclose the LE if the initial LE had the fees being paid in cash and now 3 weeks later the borrower has decided they would rather finance the fees? Is this considered a Change in Circumstance?

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Lending Compliance
#2076186 - 04/28/16 05:29 PM Re: Changed Circumstance - cash fees vs. financed Feather
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,958
Galveston, TX
No
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#2076187 - 04/28/16 05:38 PM Re: Changed Circumstance - cash fees vs. financed Feather
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 8,701
OK
Agree with Randy that you don't have to, but are you willing to live with your originally stated origination fee and any other fees (transfer taxes, etc.) that are related to your loan amount? If the customer is asking to increase the loan amount (which by nature of asking to finance the fees, i would think they are) you CAN re-disclose the LE (if you do so within 3 business days of the request) to capture those increased fees.
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