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#1839384 - 08/05/13 04:01 PM GFE Timing with Changed Circumstance
HR Banker Offline
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Joined: Oct 2002
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If we have to issue a new GFE due to changed circumstance then does the closing have to wait 7 business days after the date of the new GFE?

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Lending Compliance
#1839391 - 08/05/13 04:11 PM Re: GFE Timing with Changed Circumstance HR Banker
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,512
Bloomington, IN
That waiting period only applies if a revised ETIL had to be issued.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1839392 - 08/05/13 04:18 PM Re: GFE Timing with Changed Circumstance Dan Persfull
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The loan amount has changed due to misunderstanding of the customer. So everything has to be redisclosed and close in 7 business days, right?

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#1839393 - 08/05/13 04:19 PM Re: GFE Timing with Changed Circumstance HR Banker
#Just Jay Offline
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#Just Jay
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Cheeseheadland
And don't confuse your waiting periods either! The seven day period to close is different than the 3/6 day waiting period for a redisclosed TIL.
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#1839396 - 08/05/13 04:24 PM Re: GFE Timing with Changed Circumstance HR Banker
#Just Jay Offline
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#Just Jay
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Cheeseheadland
A change in loan amount will not require a new GFE, unless you have an orig fee tied to the loan amount and it will be increasing, in which case you have three days to redisclose, and the GFE can be at the closing table if the loan is set to close within those three days.

It will be prudent to rerun your TIL to ensure the APR has not changed significantly, and if it has, then you have to wait either three or six days after your have redisclosed, depending if you hand delievered or mailed the redisclosure.
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#1839405 - 08/05/13 04:31 PM Re: GFE Timing with Changed Circumstance #Just Jay
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Joined: Oct 2002
Posts: 1,027
Our compliance officer is off today so as a former comp. officer I'm getting the question. I thought the "changed circumstance" of new loan amount needed a new GFE. Obviously all number are now changing so the ETIL is affected as well. So we were thinking that everything needs redisclosed and just trying to figure out when this loan can close. It was at the closing today that the customer realized the loan amount was not including $$ they were expecting to pay off another debt.

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#1839425 - 08/05/13 05:11 PM Re: GFE Timing with Changed Circumstance HR Banker
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,512
Bloomington, IN
There is no waiting period for a revised GFE. A change in the loan amount does not require a revised GFE as long as the bank is willing to live with the fees disclosed.

If the changed loan amount causes the ETIL's APR to be out of tolerance then if you provide a revised ETIL face to face there would be a 3 business day waiting period. If you mail the revised ETIL there will be a 6 business day waiting period.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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