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LE redisclosure timing

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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?
Answer: 

Unless there is a changed circumstance, and you are issuing a revised LE to reset your fee tolerance baselines within three business days of learning of the change, when you issue a courtesy LE to the borrower is really up to you. There is no "timing" for a courtesy LE.

First published on 07/03/2022

Filed under lending as: 

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