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#2101001 - 09/29/16 03:59 PM Missed Fee- Lender Cure- Revised Loan Estimate
Dodge Offline
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Joined: Mar 2010
Posts: 238
Re-issuing a Loan Estimate due to a valid change circumstance. However, when reviewing the original Loan Estimate it was caught that a fee that is subject to zero tolerance was not disclosed, Bank's fault.

On the revised Loan Estimate do when need to disclose the missed zero tolerance fee? I think no because there is no way to show a Lender Cure on the Loan Estimate. However, I could be wrong...

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TRID - TILA/RESPA Integrated Disclosures Rule
#2101019 - 09/29/16 04:40 PM Re: Missed Fee- Lender Cure- Revised Loan Estimate Dodge
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,281
Galveston, TX
Yes - all fees should be updated. It does not impact your tolerance calculations.
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#2101030 - 09/29/16 05:11 PM Re: Missed Fee- Lender Cure- Revised Loan Estimate rlcarey
Cornfed Turtle Offline
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Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
This is a daily argument at my bank. The residential folks want to update the LE with the most up to date information and the CO says everything stays the same on the revision except the COC.

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#2101047 - 09/29/16 06:04 PM Re: Missed Fee- Lender Cure- Revised Loan Estimate Dodge
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,281
Galveston, TX
Tell your CO that 1026.17(c)(2)(i) already requires it as pointed out by the CFPB in the proposed updates:

Consistent with § 1026.17(c)(2)(i), the Bureau also proposes to add new comment 19(e)(3)(iv)-5 to clarify that, regardless of whether a creditor issues a revised Loan Estimate to reset tolerances or simply for informational purposes, § 1026.17(c)(2)(i) requires that any disclosures on the revised Loan Estimate must be based on the best information reasonably available to the creditor at the time the disclosure is provided to the consumer.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2101049 - 09/29/16 06:12 PM Re: Missed Fee- Lender Cure- Revised Loan Estimate rlcarey
Cornfed Turtle Offline
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Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
If you start getting bombarded with thank you notes from the Midwest....it's my res staff. I already forwarded this to our ops person.

I was fully expecting them to try to implement some "second LE" with up-to-date information on it.

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