TRID: Changed Circumstances, Tolerances & Providing Revised Loan Estimates – ON-DEMAND WEBINARS

Date Recorded: December 30, 2021

Presenter: Anetria Cohen, CRCM, Vice President, FORVIS

Creditors are responsible for ensuring that the disclosures in the Loan Estimate are made in good faith and consistent with the best information reasonably available to the creditor at the time they are disclosed. Good faith for closing costs means that we calculate the difference between the estimated charges originally provided in the Loan Estimate with the actual charges paid by or imposed on the consumer in the Closing Disclosure, subject to certain tolerances.
But we all know it is inevitable that creditors will become aware of information during the application process that makes the disclosures provided on the original Loan Estimate wrong. When does a “changed circumstance’ occur and what is its significance? What if the creditor learns of the changed circumstance once it already has provided the Closing Disclosure?

This webinar will provide an in-depth review of the tolerance rules, the definition of changed circumstances, and how and when creditors provide a revised estimate.

HERE IS WHAT YOU WILL LEARN:

Good Faith Determination for Estimate of Closing Costs

• The zero percent tolerance category
• The aggregate ten percent tolerance category
• Variations permitted for certain charges

Revised Loan Estimates

• Changed Circumstances affecting settlement charges
• Changed circumstances affecting eligibility
• Revisions requested by the consumer
• Interest rate dependent charges
• Expiration
• Delayed settlement date on a construction loan

Provision and Receipt of Revised Loan Estimates

Revised estimates in Closing Disclosures