Not sure I agree on the revised CD. I would do a short year escrow analysis so they don't have a payment shock next year. I would equate it to this example in the commentary if this change transpired between the customer and the insurance agent.
iv. Assume consummation occurs on a Monday and the security instrument is recorded on Tuesday, the day after consummation. Assume further that ten days after consummation the municipality in which the property is located raises property tax rates effective after the date on which settlement concludes. Section 1026.19(f)(2)(iii) does not require the creditor to provide the consumer with corrected disclosures because the increase in property tax rates is not in connection with the settlement of the transaction.
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