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#2218829 - 07/31/19 04:01 PM Unlock rate lock
mmason Offline
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Joined: Nov 2001
Posts: 447
New England
We have a customer who wanted to lock the rate so that is what we disclosed on the LE. Now he wants to unlock the rate and keep it floating. Do we need to reissue the LE?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2218832 - 07/31/19 04:10 PM Re: Unlock rate lock mmason
mmason Offline
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Joined: Nov 2001
Posts: 447
New England
I should add that the initial LE was issued as locked based on the loan officer's discussion with the customer. We do not have a signed rate lock agreement.

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#2218835 - 07/31/19 04:35 PM Re: Unlock rate lock mmason
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
Without a written rate lock agreement, a rate is never locked.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2218839 - 07/31/19 04:52 PM Re: Unlock rate lock mmason
mmason Offline
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Joined: Nov 2001
Posts: 447
New England
I agree; however, the LE was issued as locked based on the customer's verbal request. So do we need to provide an accurate LE now to show it's not locked?

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#2218842 - 07/31/19 05:13 PM Re: Unlock rate lock mmason
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
It is going to be a business decision, there is no guidance as to how to correct. You can't actually cure the original violation. But sending a corrected informational LE to make sure the consumer knows the rate is not locked might not be a bad idea.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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