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#2093233 - 08/15/16 04:19 PM Request for LE after 3 days
ComplianceNewby Offline
100 Club
ComplianceNewby
Joined: Feb 2014
Posts: 110
Louisiana
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?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2093284 - 08/15/16 06:35 PM Re: Request for LE after 3 days ComplianceNewby
ScoutLaRue Offline
Member
Joined: Jul 2016
Posts: 73
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.

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#2093288 - 08/15/16 06:39 PM Re: Request for LE after 3 days ComplianceNewby
TMatt87 Online
Diamond Poster
TMatt87
Joined: May 2011
Posts: 1,987
Idaho
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.
_________________________
All opinions are my own, not my employer's

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#2093325 - 08/15/16 07:48 PM Re: Request for LE after 3 days ComplianceNewby
Shellfish Offline
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.

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#2103538 - 10/18/16 08:42 PM Re: Request for LE after 3 days ComplianceNewby
Christine81 Offline
Member
Joined: Mar 2011
Posts: 78
TMatt87, would you direct me to where the penalty is spelled out? I would like to share that with my Lenders. Thanks.

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#2103848 - 10/20/16 01:22 PM Re: Request for LE after 3 days ComplianceNewby
Compliance NABW Offline
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.

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