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#2048773 - 11/09/15 05:56 PM Changed Circumstance
Newbie06 Offline
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Joined: Mar 2006
Posts: 737
A lender informed today that a loan he is working on, in which the LE was already generated and sent, for a couple of brothers. The lender was going to close the loan at the bank because the loan would have been considered a refinance due to one brother being on title of the house. At the sound of the situation I figured it would be a change in circumstance but I came to find out that the other brother is simply requesting to close at the title company for no particular reason. Now I am thinking this is not considered a changed circumstance. Correct??

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TRID - TILA/RESPA Integrated Disclosures Rule
#2048781 - 11/09/15 06:15 PM Re: Changed Circumstance Newbie06
Truffle Royale Offline

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Not sure what you're asking but I'll take a shot.
Where was it scheduled to close?
If at the bank and one of the borrowers wants to move it to the title company, that's a borrower requested change.
Borrower requests = valid CC so you can redisclose to capture the title company closing fee, if that's what you're asking.

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#2048787 - 11/09/15 06:22 PM Re: Changed Circumstance Truffle Royale
Newbie06 Offline
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Joined: Mar 2006
Posts: 737
Yes, that is what I am asking. Thank you.

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#2048791 - 11/09/15 06:26 PM Re: Changed Circumstance Newbie06
Newbie06 Offline
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Joined: Mar 2006
Posts: 737
So, the other situation I have is the application date was prior to Oct. 3rd. The lender now has a CC. Should he proceed with the old TIL/HUD or use re-disclose using new disclosures? My thinking is to proceed using the old forms.

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#2048796 - 11/09/15 06:36 PM Re: Changed Circumstance Newbie06
Truffle Royale Offline

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Posts: 17,397
Just like in 2010, if you started old you finish old.
TRID only applies to applications taken 10/3 and after.

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