Are we required to re-disclose the LE if the APR changes under the old tolerance limits? i.e. we add auto debit during the processing of the loan, the APR drops .25% because they get the lower ate for auto debit. Do we re-disclose the LE under TRID
like we had to re-disclose the TIL before? Or do we only have to re-disclose when the fee tolerances are breached or there is a change in circumstance?

Hi Ninky,

The way I understand it, as long as you are not dealing with a rate lock, a rate change does not trigger a revised LE even if it makes the APR inaccurate. You would just reflect the accurate rate with the corresponding APR on the CD that you are delivering 3 days prior to consummation anyway. If, however, you have a rate lock agreement with the lower rate, than you would need to issue a revised LE within 3 days of the new lock agreement.

Hope this helps.