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BankersOnline.com Forums Dodd-Frank Final Rules Discussions TRID - TILA/RESPA Integrated Disclosures Rule Change after Closing Disclosure Delivered
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#2257677 - 08/04/21 06:17 PM Change after Closing Disclosure Delivered
Believing... Offline
Gold Star
Joined: Apr 2012
Posts: 346
In the mountains
I'm having a foggy moment. We delivered a CD last Friday and the borrower requested more money. The request will not affect the rate/APR. Can we just increase the loan amount and affected fees, document the changed circumstances, and deliver the new CD at closing?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2257678 - 08/04/21 06:36 PM Re: Change after Closing Disclosure Delivered Believing...
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
As long as the loan closes within three business days of the request, yes.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2257679 - 08/04/21 06:42 PM Re: Change after Closing Disclosure Delivered rlcarey
Believing... Offline
Gold Star
Joined: Apr 2012
Posts: 346
In the mountains
It will not close until the 9th, so since this is the 3rd day, I need to deliver the revised CD today, correct?

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#2257682 - 08/04/21 07:06 PM Re: Change after Closing Disclosure Delivered Believing...
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
If the borrower made the request last Friday and you are not open on Saturdays - yes - if you are open on Saturday, you already missed your window.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2257683 - 08/04/21 07:07 PM Re: Change after Closing Disclosure Delivered Believing...
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
If you need to reset your tolerance baseline, yes.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2257686 - 08/04/21 07:28 PM Re: Change after Closing Disclosure Delivered Believing...
Believing... Offline
Gold Star
Joined: Apr 2012
Posts: 346
In the mountains
Yes, thank you both, we are not open on Saturdays, so we've revised today to reset tolerances.

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