TRID Tolerance Cures – ON-DEMAND WEBINARS

Recorded Date: May 26, 2022

Presenter: Anetria Cohen, JD, Vice President & Senior Consultant, FORVIS

A two-hour webinar on how to review Loan Estimates, Closing Disclosures, and documentation to determine if and how much an institution must reimburse.

Among the many rules that we have under the Truth-in-Lending/RESPA Integrated Disclosures (TRID), one continual source of concern has been the “tolerance” requirements for closing costs. The rules can be frustratingly complicated and institutions may not understand if it has to reimburse for closing costs and, if so, how much the reimbursement is.

This webinar will review these issues in an example format – given a few different scenarios, will an institution be able to charge increased costs to a consumer or will it have to reimburse? If it has to reimburse, how much will it have to reimburse? In presenting the scenarios, we will discuss the regulations that underlie the answers, including the concept of changed circumstances. We’ll also discuss an alternative or providing a tolerance reimbursement by reducing principal.

Please note that this webinar is focused on “tolerance” and closing costs under TRID. APR and finance charge reimbursements are covered in other seminars and webinars.

HERE IS WHAT YOU WILL LEARN:

• Scenarios
  • Creditor provides the LE in good faith and not in good faith
  • Creditor learns of information during the application process (what constitutes a changed circumstance)
  • Learning of changed circumstances in the Closing Disclosure period
• Comparing the LE (or revised LE) with a Closing Disclosure
• Determining tolerance cures