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#2148940 - 10/05/17 10:15 PM expired lock
Mike T Offline
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Joined: Dec 2016
Posts: 74
If the lock expired but we relocked the loan at no costs. There were no additional costs associated with the lock nor did the pricing increased. However, the loan amount increased hence title charges increased, including the origination fee. That said, will the change of circumstances with the loan estimate reset the baseline? Or will the baseline be from the previous LE.
The processor forgot to send the LE for the extension in addition to the loan amount increase...

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TRID - TILA/RESPA Integrated Disclosures Rule
#2148948 - 10/06/17 01:07 AM Re: expired lock Mike T
Truffle Royale Offline

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You have two CoCs here. One was the relock and one was the loan amount increase. You can combine multiple CoCs into one redisclosed LE.

Unless the loan amount increase was a result of the relock, then redisclosing for just the loan amount is fine. You'll just have a technical violation for not including the extension info in the LE.

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#2148951 - 10/06/17 10:35 AM Re: expired lock Mike T
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
But if you missed the three day window on both - you are stuck with your original baselines.
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#2149018 - 10/06/17 02:57 PM Re: expired lock Mike T
Truffle Royale Offline

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I read that differently than you, Randy. I thought Mike T said that the processer sent the LE for the loan amount increase but didn't send one for the extension.
Mike, can you please clarify?

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#2149286 - 10/10/17 06:18 PM Re: expired lock Mike T
Mike T Offline
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Joined: Dec 2016
Posts: 74
didn't send one for the extension.

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#2149325 - 10/10/17 08:22 PM Re: expired lock Mike T
Compliance NABW Offline
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Joined: Oct 2015
Posts: 1,669
So, there is a revised LE that disclosed the loan amount increase and the associated fee increases?

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