Answer:
You do not need to give any new disclosures in this scenario.
First published on BankersOnline.com 7/30/12
Redisclose if Give New Rate and Within Tolerances?
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Question:
At the time of an application the rate was 3.79% and was displayed as such on all required disclosures. We are portfolio lenders so when our rates went down a little to 3.75% I gave the new rate to the customer but did not redisclose anything because we were still within the tolerances. Our compliance officer disagrees with me and thinks that I am required to redisclose. What is your opinion?
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