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#2272048 - 06/23/22 09:17 PM Adding a Co-Borrower
OldSchoolBanker Offline
Platinum Poster
Joined: May 2005
Posts: 660
We are looking at the following scenario and need some guidance.
1) Application started as an individual application. Loan Estimate provided in appropriate timeframe and esigned by borrower.
2) Co-Borrower is added several weeks later 5/9
3) The new disclosures were prepared 5/17 (outside of the 3 day Change of Circumstance window.

The originator believes the loan should be cancelled due to the missed 3 day window and then start a new application. This does not seem like a cure to me as it is no different than moving forward with the original loan outside the 3 day window.

Any feedback is appreciated.

Thanks in advance!
Old School Banker

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TRID - TILA/RESPA Integrated Disclosures Rule
#2272050 - 06/23/22 10:04 PM Re: Adding a Co-Borrower OldSchoolBanker
rlcarey Online
10K Club
Joined: Jul 2001
Posts: 79,293
Galveston, TX
Plain and simple - you missed the three-day window to increase your baseline for any fees that increased due to adding an applicant. Lenders do not get a do-over. If you were going to require that the applicant withdraw their application and submit a new joint application, it would have had to happen at that time.
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