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#1324749 - 01/14/10 06:30 PM Use of old GFE Form after 1/1/2010
wlp789 Offline
New Poster
Joined: Jan 2008
Posts: 14
WA
I agree with David that if an old GFE was issued, there is no requirement to issue a revised GFE; however, if the bank chose to, could they do so on the old GFE? The problem is that secondary market investors are requiring for applications where an old GFE was provided and where anything changes, banks are required by the investor to provide a new GFE; therefore, in this instance would they close on the new or old HUD? I believe the new.

The following threads appear to contradict one another, so I am a little confused.

"I agree that you must use the new GFE for any GFE's issued in 2010, unless it is a revised GFE - then you can stay with the old" and "The old GFE died on 12/31/09. If you issue a GFE in 2010, it MUST be on the new form"

Thank you!

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RESPA
#1334020 - 01/29/10 05:57 PM Re: Use of old GFE Form after 1/1/2010 wlp789
Truffle Royale Offline

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Joined: Jul 2003
Posts: 17,421
First, you don't have to redisclose a revised GFE for a GFE originally given in 2009.

Second, if you chose to, follow the response HUD gave above:
Quote:
In the case presented this is a borrower requested change which constitutes a change circumstance. You would issue a revise GFE using the old form since the original inception date of the application and disclosure was in 2009 and you did not originally disclose using the new GFE.


Your investor is requiring a new GFE meaning a revised one, correct? But they're not dictating the GFE form (old or new) to use, right? If they say you have to use the new form, copy and paste the HUD response here and send it to them. My experience is when faced with a properly documented response, the investor will back down.

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