Fee Change - Additional Disclosures & Wait Period?

Question:

I have a question regarding the three day wait after giving a customer a TIL. Our customer applied, and we had her sign all early docs. The only change in fees from the early docs is a $10 increase in Title Insurance Premium. Do we need to issue a new GF/TIL and wait an additional three days, or is there a certain allowance we have for situations like that? Also, once we receive the Final HUD from the Title Co., if fees are changed, do we have to reissue and wait an additional three days?

Answer:

There is no wait after issuing a GFE. However, the P-TIL disclosure is another story. If the APR is out of tolerance (I'm uncertain by the info you provided), you must issue a new P-TIL and wait three "precise business days" (M-S) after is is received by the applicant. If you mail it, you must wait three "precise business days" for them to receive it. Refer to Section 226.19(a)(1) for more info.

First published on BankersOnline.com 1/25/10