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APR Understated: Reimbursable Violation?

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Question: 
Through an internal audit we found a real estate loan in which the preliminary APR was understated, so corrected disclosures were provided at closing. The issue is, the customer received the corrected disclosures at closing instead of three business days prior to closing. Is this a reimbursable violation?
Answer: 

This doesn't make the loan reimbursable. You violated the timing requirement, but there's nothing you can do about it once the loan is closed. Note it, train and move on.

First published on BankersOnline.com 8/30/10

First published on 08/30/2010

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