Skip to content
BOL Conferences
Thread Options
#2147665 - 09/26/17 07:28 PM Revised closing disclosure for change in loan term
CindyT Offline
New Poster
Joined: Sep 2015
Posts: 18
I've been researching whether a revised CD is required due to a change in the loan term from 15 years to 20 years and have been finding conflicting answers. The APR did not change (we kept the same rate and fees), we did not add a prepayment penalty and the specific loan product (fixed rate) did not change. However, the loan term did change - is that considered a feature of the loan product? Would we need to re-disclose and allow an additional 3 days?

Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2147668 - 09/26/17 07:37 PM Re: Revised closing disclosure for change in loan term CindyT
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
Would we need to re-disclose - Yes

allow an additional 3 days - No
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#2147748 - 09/27/17 02:01 PM Re: Revised closing disclosure for change in loan term CindyT
John_Burnett Offline
Gold Star
John_Burnett
Joined: Feb 2013
Posts: 312
Cape Cod
I agree with Dan. The description of the "Product" under Loan Information at the top of page 1 of the closing disclosure was "Fixed Rate" before the change and "Fixed Rate" after the change. Since it didn't change, the APR remained accurate, and you didn't add a prepayment penalty, there is no additional "wait" imposed on closing.
_________________________



Return to Top
#2147850 - 09/27/17 08:12 PM Re: Revised closing disclosure for change in loan term CindyT
CindyT Offline
New Poster
Joined: Sep 2015
Posts: 18
Thank you both for your expertise!

Return to Top