When it comes to changed circumstances for TRID, it ultimately comes down to what did you know and when did you know it. For example, if you typically charge an applicant for a credit report, it should be included on the initial Loan Estimate. If you fail to include it, whether intentionally or by mistake, you don’t get to add that fee back if you revise the Loan Estimate later. The only way that fee could be added back to the Loan Estimate would be if you have a valid changed circumstance that relates specifically to the credit report fee. Anytime you add a fee that wasn’t on a prior disclosure, you can be sure that examiners are going to be looking to see 1) if you had a valid changed circumstance; 2) when you learned of the changed circumstance; and 3) if you got a revised Loan Estimate out within three business days.
Jerod explains more in the video.
Published
2025/03/11
