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Our secondary market mortgage department issues a Closing Cost Worksheet, we have confirmed it meets the requirements outlined in TRID. Once the LE has been provided, if changes are made can a new Closing Cost Worksheet be provided as long as it is in conjunction with a new LE? Or, are we not allowed to provide at all since an LE has been provided?
You would not be able to issue the worksheet after you have issued the LE.
From the preamble to the final rule: The Bureau is deleting the proposed timing requirement that the written estimate be provided before the consumer has indicated an intent to proceed with the transaction. The Bureau believes that this requirement
suggests that a written estimate could be provided even though the Loan Estimate
had been provided. The Bureau believes receiving a written estimate after the Loan Estimate has been provided will confuse consumers and create compliance burdens for industry.Can you provide the closing Cost Worksheet in the same disclosure packet with the LE? It does meet the requirement in the regulation with the necessary verbiage on top and is not in the same format as the LE.
From the preamble p. 139:
The final rule also does not include a separate definition of application for pre-approval estimates or worksheets. Creditors are currently able to issue such documents at any time before issuing the RESPA GFE and the early TILA disclosure, and will continue to be able to do so under this final rule. Further, the Bureau believes that creating another definition of application would create consumer confusion and add to regulatory burden.
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