Initial CD issued 2/20- revised CD issued 2/21 under a valid Change of Circumstance- The revised CD was signed by the borrower 2/21, 4 business days prior to closing. QC is asking for evidence the 2/20 CD was received by the borrower 3 business days prior to closing. I don't think this is necessary since we have evidence the 2/21 CD was received timely. Can anyone confirm?

As long as the initial CD had an issue date of 2/20, and the revised CD had an issue date of 02/21 on it, so the borrower could determine which one was issued last, I am not sure what the problem might be. Signatures on CDs are an investor or lender requirement, not one of regulation. The regulations only require delivery.

Thank you-