CFPB TRID Sec. 8 - May a creditor use a revised Loan Estimate if the consumer requests revisions to the terms or charges?

Compliance > Regulation Z - TILA / TRID Specific > Loan Estimates
Q:  May a creditor use a revised Loan Estimate if the consumer requests revisions to the terms or charges?
 
A:  Yes. A creditor may use a revised Loan Estimate to reset tolerances if the consumer requests revisions to the credit terms or settlement that affect items disclosed on the Loan Estimate and cause an estimated charge to increase. (§ 1026.19(e)(3)(iv)(C); Comment 19(e)(3)(iv)(C)-1)
 
Remember, providing a revised Loan Estimate allows creditors to compare the updated figures for charges that have increased due to an event that allows for redisclosure to the amount actually charged for those services. If amounts decrease or increase only to an extent that does not exceed the applicable tolerance, the Loan Estimate is still deemed to be in good faith. Redisclosure is permissible in these circumstances, but will not reset the tolerances, and creditors must continue to measure the tolerances against the original Loan Estimate. (§ 1026.19(e)(4)(i))
 
A creditor may also use a Closing Disclosure or corrected Closing Disclosure to reset tolerances when a consumer requests revisions. (§ 1026.19(e)(4)). For information about using Closing Disclosures to reset tolerances, see sections 10.3, 11.11, 12.2 and 12.3 below (in the Bureau’s compliance guide.)
 
 
This Loan Estimate / LE information can be found in the CFPB's TILA-RESPA Integrated Disclosure rule compliance guide - http://www.consumerfinance.gov/regulatory-implementation/tila-respa/
 

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