Revising The Loan Estimate & Correcting The Closing Disclosure: When & How to Provide Additional Disclosures – ON-DEMAND WEBINARS

Date Recorded: March 2, 2022

Presenter: Anetria Cohen, Vice President and Senior Consultant, FORVIS

The Truth-in-Lending/RESPA integrated disclosure (TRID) rules for providing the Loan Estimate and Closing Disclosure can be deceptively complicated. Often, for example, an institution will realize that certain information on a Loan Estimate has become wrong… well, we just provide a revised Loan Estimate and use that one for comparing tolerance of fees, right? That’s an incorrect understanding of the rule – it’s much more complicated than that.

This webinar will focus on the rules that provide for when and how a creditor may revise a Loan Estimate (LE) and correct a Closing Disclosure (CD). Can a creditor provide a revised LE if the loan amount or fees have decreased? When does the creditor have to compare a Closing Disclosure with the original LE instead of a revised LE? When does a creditor have to give the consumer a new waiting period? Can the creditor cure a violation of a CD provided at closing? Can a CD cure a tolerance violation?

This webinar will discuss in detail the rules for correcting disclosures. We will discuss the importance of understanding tolerance and the effect of changes on when we need to, and we do not need to, provide corrected disclosures. We will also discuss the importance of timing and how to provide corrected disclosures.

HERE IS WHAT YOU WILL LEARN:

The webinar will include the following topics:

• Tolerance
• The valid reasons for revising a LE
• Whether a creditor can provide a revised LE for purposes other than tolerance issues
• The timing of providing a revised LE
• Changes that require a new waiting period for a corrected CD
• APR tolerance review
• Changes to the CD after closing
• Timing of providing a corrected CD