Adding Co-Borrower After Closing Disclosure

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Question:

If an early Closing Disclosure has been issued and the borrower now wants to add a co-borrower, what are the compliance issues that need to be reviewed? Under Reg Z, is there a new 7 day waiting period to close due to a 'new' application' with the co borrower? Do we go off of the date of application of the 'co borrower' or the original primary borrower application? This is not technically a changed circumstance, but if no fees are increased that break tolerances, nor a program change, is there an issue?

Answer:

There aren't any issues. There's no requirement that both borrowers receive a loan estimate or (except in the case of a co-borrower who has a right to rescind) closing disclosure. As a courtesy, I suggest providing a copy of the closing disclosure at closing, but there's no impact on timing.