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#2159683 - 01/09/18 02:06 PM TRID Closing Disclosure
Vikingriver Offline
New Poster

Registered: 11/15/13
Posts: 1
When preparing the final CD which includes paying off a loan at our institutions, what happens if the borrower makes a payment on
the loan to be paid off just prior to the closing and it makes the prepared CD inaccurate? The payment made might not be determined until after the closing. Should we be sending a corrected CD along with the refund check? Or is the original CD acceptable with the refund check?
Thank you.

TRID - TILA/RESPA Integrated Disclosures Rule
#2159693 - 01/09/18 02:29 PM Re: TRID Closing Disclosure [Re: Vikingriver]
rlcarey Online
10K Club

Registered: 07/16/01
Posts: 68582
Loc: Galveston, TX
Since is impacts the cash to close table and the payoff amount, a revised CD should be provided with the refund check.
The opinions expressed here should not be construed to be those of my employer:

#2159718 - 01/09/18 03:14 PM Re: TRID Closing Disclosure [Re: Vikingriver]
John Burnett Offline

10K Club

Registered: 10/27/00
Posts: 37456
Loc: Cape Cod
Absolutely. The change in payoff affects an amount paid by the consumer. Corrected CD with Issue date equal to the date you send it, along with the refund check (unless the check has been sent earlier).
John S. Burnett
Professional Compliance Nerd since 1976
Bankers' Threads User #8

#2159809 - 01/09/18 07:21 PM Re: TRID Closing Disclosure [Re: Vikingriver]
RR Joker Offline
10K Club

Registered: 11/15/02
Posts: 20266
Loc: The Swamp
I reported this to be moved [wrong forum]. Is that another feature of BOL that no longer works? [just curious]
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour