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#2240018 - 07/23/20 02:47 PM Starting a new app when fee wasn't disclosed
It's not easy Offline
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Joined: May 2009
Posts: 128
If the business lines forgot to disclosure MI and they aren't allowed to do a CIC to pass the fee onto the borrower since it was a bank error, can they withdraw the application and start over? I remember see a discussion on this when TRID first rolled out but wasn't able to find anything on it. Wouldn't it have to be the borrower who wanted to withdraw the file anyways? Thanks!

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TRID - TILA/RESPA Integrated Disclosures Rule
#2240020 - 07/23/20 02:48 PM Re: Starting a new app when fee wasn't disclosed It's not easy
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
For the loan to be withdrawn the borrower must 'expressly' withdraw. The bank can't do it for them.

And I would NOT do this because of a bank error.
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#2240022 - 07/23/20 02:54 PM Re: Starting a new app when fee wasn't disclosed It's not easy
It's not easy Offline
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Joined: May 2009
Posts: 128
My thoughts exactly, but wanted to make sure I wasn't being to conservative as the business line puts it. Thanks!

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#2240029 - 07/23/20 03:51 PM Re: Starting a new app when fee wasn't disclosed It's not easy
Skittles Online
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Skittles
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Posts: 13,965
TN
You are not being too conservative - and what customer would withdraw an application just so they could pay more fees?
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#2240214 - 07/27/20 07:37 PM Re: Starting a new app when fee wasn't disclosed It's not easy
John Burnett Offline
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John Burnett
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Cape Cod
The business line has to bear the cost of its flubs.
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BankersOnline.com
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