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How to Handle Tolerance Issue on Real Estate Loan

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Question: 
On consumer real estate loans, when we have a tolerance issue between prelim disclosures to final documents, we have been providing a revised GFE at closing. Can you tell me if this is an appropriate way to handle this?
Answer: 

You can only revise a GFE when a qualified changed circumstance exists and you must issue the revised GFE within 3 business days of when your learned of the changed circumstances or it is not valid.

Incorrectly disclosing a fee is not a changed circumstance. And based on your statement you most likely have several tolerance cures you need to go back and cure.

I suggest you review 1024.7, the 4/2/10 RESPA FAQs, and the RoundUp publications.

First published on BankersOnline.com 5/20/13

First published on 05/20/2013

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