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