Question:
Our company chooses to redisclose a Loan Estimate (LE) anytime a loan amount changes. I understand the requirements for when a loan amount would create the need for redisclosure but I have a question on the required timing for this. Being this is the path we choose to take and send redidsclosures as a curtesy on any change, would the 3-day clock start when the loan amount is actually changed in the system or when it's requested by the borrower?
I realize we're making things a little more difficult in determining the date of discovery but it's my stance that the actual change itself should be the trigger for the start of the clock. What is correct?
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