Skip to content

Rate Lock Extension Fee Incorrectly Disclosed

Answered by: 

If a Rate Lock Extension Fee was incorrectly disclosed on a revised CD as Origination Points, can this be corrected with another revised CD before closing, or corrected on the final consummation CD?

Yes, it can and should be corrected. There's no need to issue a revised closing disclosure before closing, but the consumer should receive it at the closing.

However, if that rate lock extension fee was not on a loan estimate issued before the closing disclosure (as might be the case if the rate lock extension was executed just before the closing disclosure was issued), there could be a problem, since the closing disclosure will have been the initial estimate of that fee (in lieu of a revised LE). At closing, it could be argued that the fee when correctly disclosed creates a 0% tolerance error, requiring a lender credit cure.

First published on 06/30/2019

Filed under: 

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics