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#2118414 - 02/15/17 05:31 PM Issuing Revised CD's
ADN Offline
100 Club

Registered: 03/15/07
Posts: 116
In auditing files, it appears our bank is issuing a lot of revised CD's (well over 60%) due to insurance and appraiser invoices coming in at the last day(s) prior to closing and these fees needing to be updated. I want big of an issue does this appear to other compliance/management professionals? Each time I bring this topic up I get a lot of resistance by the loan officers saying they are just trying to meet contract deadlines.

TRID - TILA/RESPA Integrated Disclosures Rule
#2118421 - 02/15/17 05:50 PM Re: Issuing Revised CD's [Re: ADN]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 61590
Loc: Galveston, TX
You mean a revised CD is delivered at closing - it is not that unusual. Insurance updates might be one thing, because that is controllable only by the customer. Why would the bank not know what the appraiser is going to charge. Isn't it already outlined in your appraisal engagement letter?
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#2118440 - 02/16/17 08:34 AM Re: Issuing Revised CD's [Re: ADN]
RR Joker Offline
10K Club

Registered: 11/15/02
Posts: 18491
Loc: The Swamp
We wouldn't know the appraisal amount up front, but I've not had an instance where I didn't know the invoiced amount prior to needing to send/deliver the CloD. We also rarely utilize appraisal delivery waivers either, though. which could additionally squeeze timing.
My opinion only. Not legal advice.

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