If a processor disclosed a refinance using the cash to close table for the LE with a seller and another processor changes it to the cash to close table without a seller to "fix" it, can this be corrected by sending the borrower a "corrected" CD, (post closing) changing it back to how it was disclosed on the LE? The investors are refusing to purchase the loan due to the cash to close tables not matching, even though the information is the same.

We have determined the root cause, but trying to figure out how to get this loan purchased.

You need to talk to the investor. Likely you have a portfolio loan on your hands. The cash to close table on the standard versus the alternative are entirely different and switching formats midstream is not allowed in the regulation.

As Randy stated, you have a violation that can't be fixed. So, you're really at the mercy of the investor and whether they are willing to buy it with the violation.

Not what I wanted to hear! They thought they were correcting something when in fact we created a bigger issue. Good intentions! All the information is the same, just in a different format.

I'm going to tag onto this. I found two issues of this during an internal audit I performed. I know that the 'Standard' table can be used on any loan, including refinances or home equity loans. Do any of you limit your processors to only using the standard table - and if you do - how do you disclose payoffs, etc. on this table?

I'm being asked - and told the loan operations staff that I would check.

Thank you!

You could - but using the standard format for a non-seller transaction is a lot harder to get correct. Pay-offs would be listed in Section K in Adjustments - so if you have a lot of payoffs, then you need to be able to produce a compliant addendum.

Also - some investors are starting to reject non-seller transactions on the standard format.

The loans I'm referring to are portfolio loans. We do more portfolio than secondary, which is different.

As always - thanks Randy - I'm going to do some further research.