After all the training, we still have a loan officer who made a request for a Loan Estimate more than 3 days after application. What are the consequences of being out of tolerance for disclosing after 3 days?
Also wondering this... I am new to this institution--there was no compliance officer here for several months. I caught 1 or 2 they missed providing an LE on while reviewing the backed up AA's.
For FDIC banks, the maximum civil money penalty for each occurrence of late disclosures is $4,000. Max goes way up if a pattern or practice is detected.
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All opinions are my own, not my employer's
#2093325 - 08/15/1607:48 PMRe: Request for LE after 3 days ComplianceNewby
Shellfish
Junior Member
Joined: Dec 2015
Posts: 44
In addition to possible civil money penalties, most investors will not buy a loan if it has a late LE. In my opinion, banks should have a daily report that is closely monitored to ensure LEs go out timely. I wouldn't leave it up to the loan officer due to the high risk.
#2103848 - 10/20/1601:22 PMRe: Request for LE after 3 days ComplianceNewby
Compliance NABW
Diamond Poster
Joined: Oct 2015
Posts: 1,669
This came up on another thread. I would try to get an LE out ASAP for anything that is still active. Some institutions are giving borrowers "fee-free" loans in these instances, but the official penalty is as mentioned above.