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Did You Know... 7/16/18

Blog posted On July 13, 2018

Did You Know

Be sure your borrower(s) acknowledge all LE’s provided.  If an LE has not been acknowledged, it could delay the CD going out to the borrower.  Why?

  • The last revised Loan Estimate (LE) must be “received,” at least 4 business days prior to signing
  • The initial Closing Disclosure (CD) must be “received,” at least 3 business days prior to signing

 

Example:  If an LE goes out today and the borrower does not acknowledge it the borrower must wait 4 days from that acknowledgement to sign. The waiting time on a CD is 3 business days, but the CD wait time DOES NOT supersede the LE wait time.  Once the borrower acknowledges the re-disclosed LE, the 4 business day wait begins. If we have sent out a CD, the borrower still must meet the 4 day waiting period on the LE.

Link:  http://files.consumerfinance.gov/f/201403_cfpb_tila-respa-integrated-disclosure-rule_compliance-guide.pdf