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?

There is no such thing as a CIC form. Whatever you have is an internal document.

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:


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.

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?

Adam, I didn't see your post until now. Thank you!