TRID Changed Circumstances

When it comes to determining whether you have a changed circumstance, it comes down to what you knew and when you knew it. For example, if you've done your homework on the appraisers you use and their appraisals range from $300-$500 based on a typical property in your typical lending area, then it's fair to say that you could disclose $500 on the Loan Estimate (LE) when you have applications for a typical property in your typical lending area. But what happens if you know before you issue an LE that it's not a typical property and the appraisal cost likely wouldn't be the same as a typical property? In that case, you should adjust the appraisal amount accordingly before you issue the LE. If you know the property is not typical but issue an LE with the cost for a typical appraisal, that would not be considered a changed circumstance.

Jerod explains more in the video.


TRID Resources!

Published
2024/03/14

 

Jerod Moyer

Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru. Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports-related!

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