Missed Fee- Lender Cure- Revised Loan Estimate

Re-issuing a Loan Estimate due to a valid change circumstance. However, when reviewing the original Loan Estimate it was caught that a fee that is subject to zero tolerance was not disclosed, Bank's fault.

On the revised Loan Estimate do when need to disclose the missed zero tolerance fee? I think no because there is no way to show a Lender Cure on the Loan Estimate. However, I could be wrong...

Yes - all fees should be updated. It does not impact your tolerance calculations.

This is a daily argument at my bank. The residential folks want to update the LE with the most up to date information and the CO says everything stays the same on the revision except the COC.

Tell your CO that 1026.17(c)(2)(i) already requires it as pointed out by the CFPB in the proposed updates:

Consistent with § 1026.17(c)(2)(i), the Bureau also proposes to add new comment 19(e)(3)(iv)-5 to clarify that, regardless of whether a creditor issues a revised Loan Estimate to reset tolerances or simply for informational purposes, § 1026.17(c)(2)(i) requires that any disclosures on the revised Loan Estimate must be based on the best information reasonably available to the creditor at the time the disclosure is provided to the consumer.

If you start getting bombarded with thank you notes from the Midwest....it's my res staff. I already forwarded this to our ops person.

I was fully expecting them to try to implement some "second LE" with up-to-date information on it.