Topic Options
#2199819 - 12/04/18 08:36 PM Revised LE misses appraisal fee
Karen B. Offline
100 Club

Registered: 10/17/14
Posts: 121
The initial LE quotes the appraisal fee as $500. The applicant pays the fee. Then the loan amount increases, so a revised LE is sent. The revised LE omits the appraisal fee. Will we need to do a tolerance cure on the CD? Thank you!

Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2199842 - 12/05/18 12:03 PM Re: Revised LE misses appraisal fee [Re: Karen B.]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 68231
Loc: Galveston, TX
Your baselines tolerances are set with the initial LE. You only have a good faith disclosure error on your revised LE. The secondary market might see it otherwise if you are selling the loan.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Top
#2199846 - 12/05/18 12:34 PM Re: Revised LE misses appraisal fee [Re: Karen B.]
Karen B. Offline
100 Club

Registered: 10/17/14
Posts: 121
Thank you, Randy.

Top
#2199875 - 12/05/18 04:10 PM Re: Revised LE misses appraisal fee [Re: Karen B.]
John Burnett Offline

10K Club

Registered: 10/27/00
Posts: 37387
Loc: Cape Cod
We see a lot of versions of this question where a cost is omitted or incorrectly reduced on a revised LE (or the initial CloD). That suggests that lenders need to pay more careful attention to those subsequent disclosures to ensure nothing has been omitted or incorrectly reduced. The quality control step needs to be taken BEFORE these documents are provided to the consumer. Auditors should be taking lending staff to task when they see any sort of pattern or practice reflecting inadequate QC.

End of "sermon," and I know that for most readers, I am "preaching" to the choir.

In the words of "Phil Esterhaus," "Let's be careful out there!"
_________________________
John S. Burnett
BankersOnline.com
Professional Compliance Nerd since 1976
Bankers' Threads User #8

Top
#2199878 - 12/05/18 04:24 PM Re: Revised LE misses appraisal fee [Re: Karen B.]
Karen B. Offline
100 Club

Registered: 10/17/14
Posts: 121
Thank you, John. this was a "one-off" situation, so I'm confident we wont' see it again.

Top
#2199883 - 12/05/18 04:34 PM Re: Revised LE misses appraisal fee [Re: Karen B.]
raitchjay Offline
Power Poster

Registered: 10/15/09
Posts: 7705
Loc: OK
Love the Hill Street Blues reference John....miss that show.
_________________________
I'm fixin' to fix that.

Top
#2200188 - 12/08/18 12:46 AM Re: Revised LE misses appraisal fee [Re: Karen B.]
John Burnett Offline

10K Club

Registered: 10/27/00
Posts: 37387
Loc: Cape Cod
One of my favs.
_________________________
John S. Burnett
BankersOnline.com
Professional Compliance Nerd since 1976
Bankers' Threads User #8

Top