I have a question regarding the closing date and disbursement date on the closing disclosure.
We would like to get some clarification on the proper course of action when a loan is not consummated on the estimated closing date. If our CD is issued to the borrower with an estimated (or agreed upon) closing date and for some reason the closing is delayed and therefore the disbursement date is delayed, are we required to issue a CD with a correct closing/disbursement date the actual day of closing which shows the new consummation date?
For instance, consummation is scheduled for a Monday. The borrower cannot come in for some reason and has to reschedule for Tuesday. Are we required to issue a new CD Tuesday showing Tuesday's date?
Our institution does not actually schedule or host the signing, consummation is scheduled and held at the title company or via mobile notary. With this in mind, our institution often does not know when the borrower has rescheduled for the next day or had some other delay for whatever reason. When this happens, we do not find out when the actual consummation occurs until after the fact.
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.