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#2257446 - 07/30/21 04:21 PM PMI: Disclosed, Forgot, Disclosed
Funky Falcon Offline
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Joined: Jan 2008
Posts: 242
Minnesota
We have a secondary market loan that requires PMI. The premium is escrowed and was disclosed on the Rate Lock LE. However, when issuing the CD 3 days prior to close, the PMI was mistakenly left off. The Loan Assistant realized it was missed and disclosed it on the final CD.

This was discovered in a post-closing review and the APR is out of tolerance.

We realize this was a bank error, but how do we correct this after the loan has already closed?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2257451 - 07/30/21 05:08 PM Re: PMI: Disclosed, Forgot, Disclosed Funky Falcon
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 76,962
Galveston, TX
If this an investor loan - it is going to come back if it is.

There is no cure.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2257455 - 07/30/21 05:23 PM Re: PMI: Disclosed, Forgot, Disclosed Funky Falcon
Funky Falcon Offline
100 Club
Joined: Jan 2008
Posts: 242
Minnesota
Thanks for your quick response, Randy. This is a new situation for us, so we're in the "oh cr@p, now what" phase.

You mentioned there is no cure, but if it does come back to us, would we have to pay the PMI premiums for our mistake? Or just leave it on the books as-is knowing we have a violation?

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#2257456 - 07/30/21 05:27 PM Re: PMI: Disclosed, Forgot, Disclosed Funky Falcon
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 76,962
Galveston, TX
It appears you have a disclosure violation and not a curable tolerance violation. As such, you are open to any civil liabilities and potential enforcement criticism. If the loan was subject to rescission, that most likely is still open too.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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