Skip to content
GeoDataVision
Thread Options
#2207813 - 03/05/19 05:01 PM Change in Circumstance Form vs. Revised LE
BA13 Offline
100 Club
Joined: Jul 2016
Posts: 181
We have a loan where the lender switched the loan program from FHA to Rural Development (eligibility reasons). This change directly affected the Block A as origination fees on the RD are higher than what is charged on the FHA loan. The lender listed the valid change, event date and re-disclosure date on the CIC but failed to list some of the old fees vs new fees associated with the CIC. The revised LE reflects the higher charges in Block A therefore the applicant received the correct information. Would you agree that we have a CIC form error but we don't have a tolerance issue since we have a valid CIC event?

Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2207817 - 03/05/19 05:07 PM Re: Change in Circumstance Form vs. Revised LE BA13
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,893
Galveston, TX
There is no such thing as a CIC form. Whatever you have is an internal document.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2207818 - 03/05/19 05:12 PM Re: Change in Circumstance Form vs. Revised LE BA13
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,643
In other words, your LE needs to have the correct numbers. The numbers on the CIC form (internal document) may be wrong, but have nothing to do with tolerances (other than documenting the reason for the change on the LE).

To answer your question:
Originally Posted By BA13
Would you agree that we have a CIC form error but we don't have a tolerance issue since we have a valid CIC event?


You might have an internal policy violation, but this isn't a Reg Z violation. I agree that you don't have a tolerance error just because the CIC (internal) form was completed incorrectly.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top
#2207821 - 03/05/19 05:15 PM Re: Change in Circumstance Form vs. Revised LE BA13
BA13 Offline
100 Club
Joined: Jul 2016
Posts: 181
Yes, it's an internal form we use to document the valid reason, timeframes and fee changes. Would you agree we don't have a tolerance issue for the fees in Block A?

Return to Top
#2207822 - 03/05/19 05:16 PM Re: Change in Circumstance Form vs. Revised LE BA13
BA13 Offline
100 Club
Joined: Jul 2016
Posts: 181
Adam, I didn't see your post until now. Thank you!

Return to Top