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We are concerned with trying to maintain the Good Faith standard and calculating fees for tolerance purposes. It used to be that we could only make adjustments in relation to a Change in Circumstance, but now when issuing Revised LEs we are required to look back and find anything that has changed. This could mean in comparing fees for tolerance cures when completing the CD, one fee, for example, would need to be compared to the Original LE, another fee may have to be compared to a Revised LE, and yet still another fee may need to be compared to a 2nd Revised LE. Have we been correctly informed on this process and what are your thoughts on tracking this and ensuring compliance? We use LaserPro, but have not been able to test this yet.
Since posting this question, I have listened to the recording “TRID Last Minute Update (Part 2)” and Jack addressed this issue in that webinar beginning at about the 18 minute mark. He says, and I paraphrase, that most software systems cannot handle informational disclosures because it assumes that it is a tolerance reset situation and it resets the tolerance when it shouldn’t. It may be better to stay away from issuing informational disclosures unless your software vendor has updated the system to issue them correctly. Developing a process to do these manually is an option.
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