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#2265262 - 01/26/22 07:03 PM Changed Circumstance?
mel72 Offline
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Joined: Jun 2010
Posts: 8
Can I get an opinion on the following?
If our policy states that a credit report expires after 120 days, and we have to pull new reports prior to the loan closing, can we pass those fees on to the borrower as a valid change of circumstance using the date the credit report expired and re-disclose within 3 business days?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2265265 - 01/26/22 07:14 PM Re: Changed Circumstance? mel72
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I would need to know more. Why has it taken almost 4 months to get close to closing? Was the borrower told there would need to be a fresh credit check after 120 days?
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#2265318 - 01/27/22 04:24 PM Re: Changed Circumstance? mel72
Truffle Royale Offline

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Joined: Jul 2003
Posts: 17,395
I can think of lots of reason why a loan would take literally months to get to closing. Construction delays, title issues, division of property, these are just some of the things we see here.

As to whether the borrower knows about the additional costs, we always remind the LO to tell their clients that docs are expiring and getting new ones will result in additional charges.

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