So everyone agrees that changes (any changes) that happen after the initial CD is provided must be reflected in a new CD provided at closing. A new three day waiting period after this “final” CD is provided is not necessary except under certain limited circumstances (APR becomes inaccurate, loan product changes).Changes to the loan, including a valid CIC that happens after the CD has been issued, must be reflected on a new CD that is provided to the borrower at consummation (and made available for review one day prior to consummation).A revised LE cannot be issued after issuance of the closing disclosure (CD), which must be delivered at least three business days prior to consummation.When you have a valid change in circumstance (CIC), increased fees related to the CIC can be reflected on a revised loan estimate (LE), which also resets fee tolerance limitations.
This particular issue involves increasing fees due to a valid change in circumstance (CIC) close to closing. First off, here is what everyone agrees on: So I’ll tell you what I think and you all can decide what is best to do. Even the best compliance professionals in the country disagree on this part of the regulation. My take on things comes from what I have learned from reading the regulation and the Small Entity Compliance Guide, discussions with other compliance professionals and what all of us have heard unofficially from the CFPB. There is no written guidance from the CFPB. A caveat before I provide my answer-I am just as confused as everyone else is on this particular issue. What is this? Do I need to be worried about it?ĪNSWER: Ah yes, the “black hole.” This is a very frustrating issue. QUESTION: Hey Guru, as we approach the TILA/RESPA Integrated Disclosure (TRID) implementation date, I’ve heard talk of a certain “black hole” in regards to increasing fees due to a valid change in circumstance.
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