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#2199819 - 12/04/18 08:36 PM Revised LE misses appraisal fee
Karen B. Offline
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Joined: Oct 2014
Posts: 151
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!

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TRID - TILA/RESPA Integrated Disclosures Rule
#2199842 - 12/05/18 12:03 PM Re: Revised LE misses appraisal fee Karen B.
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
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.
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#2199846 - 12/05/18 12:34 PM Re: Revised LE misses appraisal fee Karen B.
Karen B. Offline
100 Club
Joined: Oct 2014
Posts: 151
Thank you, Randy.

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#2199875 - 12/05/18 04:10 PM Re: Revised LE misses appraisal fee Karen B.
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
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!"
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2199878 - 12/05/18 04:24 PM Re: Revised LE misses appraisal fee Karen B.
Karen B. Offline
100 Club
Joined: Oct 2014
Posts: 151
Thank you, John. this was a "one-off" situation, so I'm confident we wont' see it again.

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#2199883 - 12/05/18 04:34 PM Re: Revised LE misses appraisal fee Karen B.
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 9,104
OK
Love the Hill Street Blues reference John....miss that show.
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#2200188 - 12/08/18 12:46 AM Re: Revised LE misses appraisal fee Karen B.
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
One of my favs.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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