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Correcting a Loan Estimate

Question: 
On the loan estimate, I input it as a balloon rather than installment which drastically increased the payment. Do I need to redisclose theis with a revised LE or do I make the correction in the closing disclosure?
Answer: 

by John Burnett:

Your applicant/borrower undoubtedly wonders what's going on. By all means, send a corrected loan estimate. Just remember, though, that the first loan estimate constituted a TILA/Reg Z violation which won't be expunged by the revised loan estimate. If it's an isolated incident, it may not be problematic. If it happens more often, it could trigger an exam citation.

Answer: 

by Dan Persfull:

I would like to add since this was a bank error there is no qualified changed circumstance. The new informational LE will not reset the tolerance threshold for any charges affected by the bank's mistake.

First published on 03/19/2023

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