Orig GFE:
Appraisal Fee: $2600
Owners Title Fee: $00

CIC due to borrower request to change loan programs and lower loan amount:
Appraisal Fee: $1325 (lowered to meet actual cost)
Owners Title: $2633 (forgot to include in original)

I know this is a million times wrong but now what???

DO I base my 10% tolerance on the actual appraisal fee (updated with the CIC disclosures) or from the original GFE?

I know I cant add the Owners Title in at CIC as it had nothing to do with the CIC. So I have to take that fee into consideration for my tolerance cure.

You have to go by the numbers on the LAST CORRECT GFE which was the original one.
Neither the appraisal or title fees should have been touched on your redisclosure.
So you're appraisal fee on p3 of the HUD in the GFE column should be $2600.
The owners title should be $0.

Luckily for you, these two errors are going to somewhat offset each other and thereby soften the blow of the 10% tolerance section.

thank you. that is the answer I was hoping for.:-)

CIC due to borrower request to change loan programs and lower loan amount:

A customer requested change is a qualified changed circumstance. In this case apparently the new loan program affects the appraisal cost and the lower loan amount affects the OTI.

I think in this specific instance the revised GFE based on the customer requested changes would be valid.

I disagree DAn.
They lowered the appraisal cost to meet the actual cost.
I've never seen an appraisal cost based on a loan amount or program.
Additionally, they left the OTI off the original GFE completely.
They cannot add it in when the borrower changes loan program or amount.

I think I have to go with TR on this one.

I definitely go with TR's analogy for errors on those particular fees. Well, the appraisal was just over (WAY) over quoted...that sure is high, regardless! I can't imagine a consumer RE appraisal that high! WOW!

Normally I would agree but here's my logic for this scenario.

If the borrower requested a new loan product, depending on where we were at in the process, we would treat the original request as withdrawn or approved but not accepted and process the change in products as a new loan request. But that is our process.

BTW, They lowered the appraisal cost to meet the actual cost, I totally missed that part.

That is not a CIC - that is a whole new loan application.

I'd also like clarification on what changed about the loan 'product/program'. What was it...and what is it now and why?