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Can the creditor change the loan amount on the CD instead of issuing a new LE? Example: Loan scheduled to close on Friday; on Monday the borrower decides to lower their loan amount by $10,000; change effected the APR by .125%. Can this change can be made to the CD the borrower will sign on Tuesday in order to be able to close on Friday?
You can use the closing disclosure to reflect a change in circumstance if it is too late to issue a revised LE.
Generally you compare the LE to the CD to determine tolerances. If you have a change of circumstance that allows for re-issuing the LE and resetting tolerance you would use that revised LE (or CD if it is within 4 business days of consummation and the change was, therefore, reflected on the CD) for comparing charges. The CFPB has issued a proposal that would clarify when creditors are permitted to re-issue a CD to reset tolerances (https://www.gpo.gov/fdsys/pkg/FR-2017-08-11/pdf/2017-15763.pdf).
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