[mdunker]

I am trying to figure out how we should handle our rate lock dates, I have been reviewing section 1026.37(a)(13), but am still confused. We do a lot of ARM loans in which we don’t really have have a rate lock, we honor the rate that was disclosed at the time of application. From what I have read I think we should set our rate lock date to be 90 days out in this instance, and then the all other estimated costs will be 10 days.

[rcooper]

If you aren’t locking the rate you should check “no” under the Rate Lock section of the LE.

If you do lock the rate, I am not aware of anything that says it has to be 90 days. Can you tell me where you found that information?

[mdunker]

i can’t remember where i got that information, but i thought that since we honor the rate that is disclosed at application we had to show that we did lock the rate and would want the rate lock to expire at or after our anticipated closing date.

[TheBank]

Our bank has the same practice, we honor the rate quoted at application, and do not lock the rate either. So I understand checking “No” for Rate Lock, however the paragraph below that on the LE states “All other estimated closing costs expire on X/X/XXX at X:XX XM CST. What date should we put here? The commentary does not discuss parameters. Can we put the same day the LE is issued, or next day? (even if mailed)

[mdunker]

we are going with no under the rate lock, then under the all other charges and fees going with the 10 business days at 5:00 P.M. and the time zone we are currently in.

[Anonymous]

On a changed circumstance under the other estimated closing costs expiration(page 1 of the LE), is this 10 business days from the date of the revised LE or is it the same date used on the original LE (as it was on the GFE)?

[Author]

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