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I am looking for a little guidance on disclosing daily interest on the LE. Our past practice was to always disclose 28 days of interim interest on all transactions. This would provide our applicants with the highest dollar amount that could possibly be charged. We are now being told that on the LE we should not always disclose 28 days of interest, but instead disclose what the interest would be based on an anticipated close date. That poses two issues in my mind. The first is on a purchase transaction since we no longer can require a contract at the time of application what do we use as the anticipated close date to determine how many days of interest to count? Similarly on a refinance that is not locked in what should we use as an estimated close date? While I know there could be concerns with any approach how could using a standard 28 days of interest be harmful to the applicant? Any thoughts you or your members could provide will be appreciated.
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