The "estimated closing costs expire on [date]" disclosure gives the date, which must be at least 10 business days after issuance of the original LE, by which the applicant must express an intent to proceed in order for the non-rate-related costs on the LE to be honored going forward. If the intent to proceed is received after that date, the creditor is able to issue a new LE with new cost estimates -- tossing out any of the estimates on the original LE. There is no connection here to the closing disclosure for the loan, which could be issued quickly or weeks away, depending on the situation.
If you have learned of extra title costs, you have 3 business days from obtaining that information to issue a revised LE (or, depending on timing, a closing disclosure) with the updated title costs estimate.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8