Q: Are creditors required to provide corrected Closing Disclosures if terms or costs change after consummation?
A: Yes, in some circumstances. Creditors must provide a corrected Closing Disclosure if an event in connection with the settlement occurs during the 30-calendar-day period after consummation and that event causes the Closing Disclosure to become inaccurate and results in a change to an amount paid by the consumer from what was previously disclosed. (§ 1026.19(f)(2)(iii); Comment 19(f)(2)(iii)-1). When a post-consummation event requires a corrected Closing Disclosure, the creditor must deliver or place in the mail a corrected Closing Disclosure not later than 30 calendar days after receiving information sufficient to establish that such an event has occurred. (§ 1026.19(f)(2)(iii); Comment 19(f)(2)(iii)-1)
However, a creditor is not required to provide a corrected Closing Disclosure if the only change that caused an inaccuracy is the per-diem interest and any disclosures affected by the change in per-diem interest. But, if a creditor is providing a corrected Closing Disclosure for any other reason, and the per-diem interest is also inaccurate, the creditor must provide the corrected per-diem interest (and any disclosures affected by the change in per-diem interest) as well as the other updated disclosures. (Comment 19(f)(2)(iii)-2)