In the calculating cash to close section on the Closing Disclosure, should the amounts disclosed in the Loan Estimate column match the amount disclosed on the Loan Estimate or Revised Loan Estimate? Thanks in advance.

The amounts in the Loan Estimate column on the CloD should reflect the amounts from the most recent loan estimate, whether it's the first and only LE or a revised LE.

The amounts from the loan estimate column on the CloD are used to respond YES or NO to the questions about whether there was a change (unless the only change is due to the rounding requirement for the LE). They are NOT used for determining whether any cost increase (or a reduction in Lender Credits) is a tolerance violation. That happens "off the CloD."

This is weird. In theory, you could have a situation where the answer to "did this change" is no, but is still a tolerance violation. So, you'd need to say no, but also say that is increased more than the legal limit. Talk about a nightmare for software vendors.

??? I'm not following your hypothetical situation, Compliowa.

I think it could happen if you issue a revised LE due to a rate lock, and update the fees at that time, but didn't have a valid changed circumstance. But, maybe I haven't thought this through enough or am missing something. See if this makes sense to you.

EX:
1. Initial LE - appraisal fee is estimated at $250 and it is 0 tolerance

2. Realize you made a mistake and the company you disclosed recently changed their fee to 300 but you forgot to update your template. You don't have a valid changed circumstance.

3. You lock the rate for the borrower and issue a revised LE. Since you know the appraisal cost is actually 300 you update it on the revised LE at that time. However, since you didn't have a valid changed circumstance, you are still over tolerance.

4. When you issue the CD, you use the amounts from the most recent LE which include the 300 for the appraisal. So the most recent LE and the CD match, but you still have a tolerance violation.

You're example falls apart at #4.
You use the amounts shown on the last VALID LE. So you cannot use the $300 amount for comparison to the CD because it's wrong and you know it. The LE column must be calculated using the appraisal fee of $250.

TR - you might want to read the clarification in the TRID proposal - last LE issued for any reason. Granted - still a proposal but that is where we are headed.

TR, could you cite this? It makes sense to me otherwise you run into the situation I mentioned. But, see John's post above most people are saying you use the most recent estimate.