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TRID Amendment: Total of Payments Disclosure

Question: 
Based on the TRID amendment effective 10/1/18, if a consumer decides to increase a loan amount after the initial loan estimate has been issued, is a revised LE required to comply with the new tolerance for Total of Payments disclosure?
Answer: 

by Randy Carey:

No - the tolerance for Total Payments is only based on the accuracy of the final CD.

Answer: 

by John Burnett:

There is no Total of Payments disclosure on the Loan Estimate. On what basis could a revised LE make that more accurate?

The Total of Payments is disclosed only on the CloD, under revised §1026.38(o)(1), which is also where the accuracy tolerance limits are addressed. It is strictly a closing disclosure concern, and the total of payments disclosed there is compared with the actual total of payments as determined using revised comment 38(o)(1)-1, Calculation of total of payments.

First published on 10/28/2018

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