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#2243072 - 09/24/20 06:17 PM Change the Name of a Fee in A
NoJustNo Offline
100 Club
Joined: Oct 2013
Posts: 189
Midwest
Can you change the name of a fee that was disclosed on the LE when you issue the CD without having a tolerance issue? Let's say on the LE you disclosed a fee as an "Underwriting Fee." Then when you are ready to issue the CD, you realized the "Underwriting Fee" was incorrect and should have been disclosed as points. Will that fly? There is no additional cost to the borrower - just removing one fee ("Underwriting Fee") and changing the description to points.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2243074 - 09/24/20 06:38 PM Re: Change the Name of a Fee in A NoJustNo
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,310
Galveston, TX
No.

1026.38(h)(4) The services and costs disclosed pursuant to paragraphs (f) and (g) of this section on the Closing Disclosure shall be labeled using terminology that describes the item disclosed, in a manner that is consistent with the descriptions or prescribed labels, as applicable, used for such items on the Loan Estimate pursuant to ยง 1026.37.

How can someone confuse an underwriting fee with a fee that the borrower is paying to buy down their interest rate?
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