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BankersOnline.com Forums Dodd-Frank Final Rules Discussions TRID - TILA/RESPA Integrated Disclosures Rule APR out of tolerance
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#2254362 - 05/25/21 04:08 PM APR out of tolerance
newyork Offline
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Joined: Aug 2008
Posts: 452
If, the APR is out of tolerance compared to the loan estimate APR, at the initial closing disclosure phase due to the borrower becoming responsible for more fees, is there a violation?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2254364 - 05/25/21 04:18 PM Re: APR out of tolerance newyork
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
There is no APR comparison between an LE and a CD.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2254365 - 05/25/21 04:21 PM Re: APR out of tolerance newyork
newyork Offline
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Posts: 452
Ok. At what phase of the transaction are APR's compared to check if they were disclosed correctly?

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#2254366 - 05/25/21 04:22 PM Re: APR out of tolerance newyork
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
Once you issue a CD, if the APR changes by more than the allowed tolerance it restarts your three business days to closing.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2254367 - 05/25/21 04:32 PM Re: APR out of tolerance newyork
newyork Offline
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Joined: Aug 2008
Posts: 452
Thank you!

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