[hdavis3681]

I have a scenario I would like to ask about. Recently, we originated a TRID purchase loan and included a homeowner’s insurance quote on the CD. Two days after closing, the official insurance policy was received by the bank, and the premium had decreased from the amount quoted on the CD. We have our borrowers pay for the insurance premium outside of closing, so we did not collect an excess amount that needed to be refunded.

Does this mean a revised CD should have been sent within 30 days since the amount being paid changed, or is this not required since the amount the borrower paid *within* closing did not change? It seems like this requirement applies if any amount disclosed changes, but I have also been hearing that, since homeowner’s insurance is not subject to tolerance, a corrected CD is not required in this situation.

[Kimberly Boatwright, CAMS, CRCM]

Disclosures require that your provide the best information at the time you created the CD. But you are also required to provide a revied one if something changed after you receive updated information. The positive is you do not have cure to worry about but you are required to send them an updated CD within 30-days.

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