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#2135672 - 06/23/17 07:30 PM Can rate change after CD?
mmason Offline
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Joined: Nov 2001
Posts: 447
New England
Can the rate change in the following circumstances when the rate was floating, the customer never locked the rate?
1. A CD is provided 8 days before closing. Rates increase before closing. Can the bank change the rate and provide a revised CD at closing (since the customer did not lock)?
2. CD is mailed 6 days before closing. Customer needs to reschedule so closing is postponed by a week. Rates increase (again the borrower did not lock), can the bank change the rate and provide new CD at closing?

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#2135681 - 06/23/17 07:38 PM Re: Can rate change after CD? mmason
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
1. If it causes your APR to be out of tolerance, you have to re-issue the CD and wait an additional three days.
2. See above
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#2135695 - 06/23/17 08:19 PM Re: Can rate change after CD? mmason
John Burnett Offline
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John Burnett
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Posts: 40,086
Cape Cod
But to your initial question, the issuing of the CloD doesn't commit to the final rate. But if you do change the rate, you need to know when that will create an inaccurate APR situation, which will trigger the re-issue of the CD that Randy alludes to.
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#2135782 - 06/26/17 02:05 PM Re: Can rate change after CD? John Burnett
mmason Offline
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Joined: Nov 2001
Posts: 447
New England
Thank you both. My discomfort was with changing the rate after we've issued the CD, it seems like that should be final, so thanks for the reassurance.

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