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#2253023 - 04/27/21 02:39 PM Good Faith and Changed Circumstances
compliance75 Offline
100 Club
Joined: Oct 2016
Posts: 105
If there was a change in the program requested by the customer, and we are late in redisclosing the LE, can the fees be redisclosed under a changed circumstances in the CD, or are we liable for the excess tolerance fees?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2253025 - 04/27/21 02:40 PM Re: Good Faith and Changed Circumstances compliance75
Skittles Offline
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
Are you still within the 3 day requirement for notification?
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#2253028 - 04/27/21 02:51 PM Re: Good Faith and Changed Circumstances compliance75
compliance75 Offline
100 Club
Joined: Oct 2016
Posts: 105
not anymore

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#2253033 - 04/27/21 03:00 PM Re: Good Faith and Changed Circumstances compliance75
Skittles Offline
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
If the three days have passed then you can't pass along the additional fees due to the changed circumstance. You might want to do some additional training for your staff so they recognize/understand the timing requirement.
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#2253043 - 04/27/21 03:41 PM Re: Good Faith and Changed Circumstances compliance75
compliance75 Offline
100 Club
Joined: Oct 2016
Posts: 105
thanks

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