Closed loan file. The initial LE expired in September 2020 (was not locked and Closing Cost expiration date was provided) a revised LE was issued in February 2021. The borrower did not lock the loan, the revised LE contains no expiration date. It was re-issued with an increase for the tax escrow amount and reduction in points. When the borrower did lock the loan another LE was subsequently issued with the lock expiration date, however, the transfer tax fee changed on this LE ( increased ). The compliance department is requesting a cure regarding the increase in the transfer tax, the lender states there is no violation, since the LE's were not locked and had expired.
The lender is using the transfer tax fee under the locked LE as their comparison to the closing. Time frame is initial LE in September 2020, revision in Feb 2021 and lock in April 2021. This was a purchase of a home under construction. I don't see any language on the LE's stating " you may receive a revised LE at any time prior to the 60 days before consummation".
Last edited by bean2; 09/23/21 02:06 PM.