CFPB TRID Sec. 12.8 - Is a corrected Closing Disclosure required if the interest rate is locked after the initial Closing Disclosure is provided?

Compliance > Regulation Z - TILA / TRID Specific > Closing Disclosures
Q:  Is a corrected Closing Disclosure required if the interest rate is locked after the initial Closing Disclosure is provided?
 
A:  If the interest rate is locked after the creditor provides the Closing Disclosure to the consumer, the creditor must provide a corrected Closing Disclosure if the charges or terms become inaccurate as a result of locking the rate. In that case, the creditor must provide the corrected Closing Disclosure at or before consummation. If the rate lock triggers a new three-business-day waiting period (e.g., the previously disclosed APR becomes inaccurate), the creditor must provide the corrected Closing Disclosure at least three business days before consummation.
 
The corrected Closing Disclosure must be updated to accurately disclose all interest dependent charges and terms. Additionally, as with all corrected Closing Disclosures, all of the disclosed terms and conditions must be updated based on the best information reasonably available to the creditor at the time that it provides the corrected Closing Disclosure, even if the creditor is not resetting tolerances for those charges.
 
Note:  If the charges or terms on the Closing Disclosure do not become inaccurate because of the rate lock, a corrected Closing Disclosure is not required for the rate lock.
 
 
This Closing Disclosure / CD 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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