While reviewing the Final Closing Disclosure post closing, an item raised a question. I searched forums and could not an answer so here is my question.

The closing docs are all dates 3/17 and the loan was actually signed 3/18 and disbursed one day later on 3/23. This obviously impacts the prepaid interest, in this case by $72. I believe we need a post closing revised CD and refund the borrower $72.

As a side note, the Right to Cancel was edited to reflect the correct dates and initialed by the borrower.

Anyone confirm my thought process? Thanks in advance.

Your CD could be dated three business day before closing - so I am not sure how that is a problem. There is no requirement to issue another one at closing. If the only thing that changed is the per diem interest, it does not require a post -closing CD.

See 19(f)(2)(iii) Changes due to events occurring after consummation.- Comment 2