TRID Changed Circumstances & Section C

On the Loan Estimate, Section C, “Services You Can Shop For,” has a 10% tolerance level (assuming a provider on your list is used). In other words, the fees for items disclosed in that section cannot increase by more than 10%. But what if there is a changed circumstance or even multiple changed circumstances that occur and take you over that 10% threshold? Well, the key is to look at those items collectively and not each individual item. When valid changed circumstance(s) cause those items to collectively exceed 10%, you have three business days to issue a revised Loan Estimate.

Jerod explains more in the video.


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Video Highlights:

  • Items disclosed in Section C of the Loan Estimate cannot exceed the 10% tolerance.
  • Valid changed circumstance(s) may allow tolerances to be reset.
  • Once increases collectively exceed the 10%, a revised Loan Estimate can be issued within three business days.

Published
2023/10/18

 

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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