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#2251870 - 04/06/21 03:34 PM Late Fee on LE
ckme Offline
100 Club
ckme
Joined: Sep 2002
Posts: 248
We had an error in our late fee specs and it had a limit of $10.00. We have corrected it to be just 5% of the payment amount, but if we sent an LE with the lower late fee how do we update? Is it enough to have it correct on the CD and promissory note at closing?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2251872 - 04/06/21 03:46 PM Re: Late Fee on LE ckme
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,358
Galveston, TX
The LE is not a contractual document. The only thing you have to worry about is would this be considered a UDAAP if it was a systemic problem. Your CD, based on your decision, should reflect the legal obligation contained in your note.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2251879 - 04/06/21 05:09 PM Re: Late Fee on LE ckme
Inspector Offline
Gold Star
Joined: Apr 2016
Posts: 277
I agree that UDAP is the concern. I would let the customers know about the mistake before you get to the CD.
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Opinions expressed are my own and do not reflect legal advice or the opinions of my employer.

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