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In regards to the Closing Disclsoure it is going to come up where we have an issue that the customer can’t make it closing when have a date set. Lets say we have a loan scheduled for closing we have mailed out the cd and the day before closing the customer calls and can’t make it closing, do we have to resend the cd and wait another 3 or 6 days or since the customer already has a cd we can go ahead and close the loan with out sending another cd? The items that might change are any payoffs and prepaid odd’s interest.
If you have already provided the CD and then either the APR changes, the loan product changes or you add a prepayment penalty you will need to provide corrected disclosures and ensure the customer receives the revised disclosures 3 business days before closing.
If information you provided on the CD changes but none of the three things listed above changes then you will need to provide corrected disclosures at at or before consummation – there isn’t a new waiting period.
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