Skip to content
BOL Conferences
Forums · Active Threads · Forum Rules · Mark All Read · Log In
BankersOnline.com Forums Dodd-Frank Final Rules Discussions TRID - TILA/RESPA Integrated Disclosures Rule Late Fee on LE
Thread Options
#2251870 - 04/06/21 03:34 PM Late Fee on LE
ckme Offline
Gold Star
ckme
Joined: Sep 2002
Posts: 255
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?

Return to Top
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: 83,371
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.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2251879 - 04/06/21 05:09 PM Re: Late Fee on LE ckme
Inspector Offline
Gold Star
Joined: Apr 2016
Posts: 283
I agree that UDAP is the concern. I would let the customers know about the mistake before you get to the CD.
_________________________
Opinions expressed are my own and do not reflect legal advice or the opinions of my employer.

Return to Top