When there is a valid changed circumstance with respect to a TRID-covered application, it generally gives a creditor the opportunity to re-disclose and, as a result, reset tolerances. The kicker is, however, you only have three business days from the date you receive the new information to do so. The Commentary to §1026.19(e)(3)(iv) #3 also requires you to maintain documentation of the changed circumstance. It states:
…if revised disclosures are provided because of a changed circumstance…affecting settlement costs, the creditor must be able to show compliance ... by documenting the original estimate of the cost at issue, explaining the reason for revision and how it affected settlement costs, showing that the corrected disclosure increased the estimate only to the extent that the reason for revision actually increased the cost, and showing that the timing requirements ... were satisfied.
Jerod explains more in the video.
Published 2026/04/09
