I know I have asked this before, but I could not locate it-The Loan Estimate disclosed a fee for a credit report. For some reason the initial Closing Disclosure did not contain the fee. The final Closing Disclosure did- QC is stating this is a violation and is requiring a valid CoC for the addition of the fee on the final CD.
Since the fee was disclosed on the LE this is not a violation- correct?

It does not specifically require a cure under TRID as your tolerance testing is set with the initial LE or a valid changed circumstance disclosure. However, your initial CD was not issued in good faith, and I have seen many investors require a cure based on that fact.

okay, understood and thank you!

Just want to add a bit more context here. Not only do the rules not require a cure in this instance, but the TRID 2.0 amendments stated plainly that a cure is not required.

https://files.consumerfinance.gov/f...ortgage-Disclosure-Requirements_TILA.pdf

Bottom of page 99 of the amendments:

Regarding commenters’ request for clarification as to what the impact is on tolerance
baselines when a creditor decreases an estimated charge on a revised Loan Estimate or Closing
Disclosure, current § 1026.19(e)(3)(i) states that, except as otherwise provided in
§ 1026.19(e)(3)(ii) through (iv), an estimated closing cost on the Loan Estimate is in good faith if
the charge paid by or imposed on the consumer does not exceed the amount originally disclosed.
Moreover, for purposes of determining good faith, § 1026.19(e)(3)(iv) states that in certain
circumstances a creditor may use a revised estimate of a charge instead of the estimate of the
charge originally disclosed—but the rule does not require the creditor to use a revised estimate
for purposes of determining good faith. Thus, if a creditor decreases an estimated charge on a
revised Loan Estimate or Closing Disclosure, the creditor is not required to use the decreased
estimate for purposes of determining good faith; the creditor may determine good faith by
comparing the charge paid by or imposed on the consumer versus the amount originally
disclosed.

So while yes, some investors may require a cure out of abundance of caution, the amended rules specifically state such a cure is not required.