Can we do this?

Scenario:

We issue a preliminary CD two weeks prior to closing. After CD is issued, the customer requests a change to their program (or some other change that requires a new LE).

1) Are we allowed to actually issue a new LE once a CD has been issued?
2) If so, does it just start the clock over again (meaning once the LE goes out and is executed, we can send the new Prelmin CD out the next day)?

1. No - never.
2. See #1

Thanks for the response Randy. Where can I find this in the Reg? I tried to find it before I asked the question on here.

1026.19(e)(4)(ii) Relationship between revised Loan Estimates and Closing Disclosures. The creditor shall not provide a revised version of the disclosures required under paragraph (e)(1)(i) of this section on or after the date on which the creditor provides the disclosures required under paragraph (f)(1)(i) of this section. The consumer must receive any revised version of the disclosures required under paragraph (e)(1)(i) of this section not later than four business days prior to consummation. If the revised version of the disclosures required under paragraph (e)(1)(i) of this section is not provided to the consumer in person, the consumer is considered to have received such version three business days after the creditor delivers or places such version in the mail.

There it is. Sheesh, Right under my nose! Thanks you so much Randy!

Legally speaking, that wording that Randy cites comes from the amended language that's effective June 1, 2018. But the text in the paragraph itself is actually identical to what's there now. The only thing that changed in that paragraph is the title of the paragraph.

Under the new amendments, you can do a revised CloD within three business days of learning of the changed costs triggered by the customer's requested change to reset the basis of any cost that will go up enough to trigger a tolerance cure.