Pre-closing CD and CD at closing

Posted By: Love those Regs

Pre-closing CD and CD at closing - 08/12/20 09:20 PM

I'm getting myself confused... where in Reg Z do I find where it states we have to give a CD at closing when there have been no changes to the CD that was provided at least 3 business days prior to closing? Is it only on rescindable transactions or on all TRID transactions?
Posted By: rlcarey

Re: Pre-closing CD and CD at closing - 08/12/20 09:22 PM

It is a myth perpetuated by the secondary market.
Posted By: Love those Regs

Re: Pre-closing CD and CD at closing - 08/12/20 09:30 PM

Ah, so if there have been no changes to the early CD, then re-disclosing is unnecessary for those of us that do not sell on the secondary market? I kept reading where folks were posting about giving both and I began wondering... Thank you!!!!!
Posted By: rlcarey

Re: Pre-closing CD and CD at closing - 08/13/20 12:54 PM

1026.19(f)(1)(ii) requires that a CD be delivered at least three business days prior to consummation.

Then you have:

1026.19(f)(2) Subsequent changes.

(i) Changes before consummation not requiring a new waiting period. Except as provided in paragraph (f)(2)(ii), if the disclosures provided under paragraph (f)(1)(i) of this section become inaccurate before consummation, the creditor shall provide corrected disclosures reflecting any changed terms to the consumer so that the consumer receives the corrected disclosures at or before consummation.

No where in the regulation does it say that an additional copy has to be provided to the borrowers at consummation if there are no changes subsequent to the earlier issued CD.