We just finished listening to the Total TRID Part 1 recording and I have a question. I want to make sure we have the resetting tolerance information correct.
When resetting tolerance for a changed circumstance or request by consumer, the tolerance reset is only permitted when the fees increase beyond the applicable tolerance threshold (0% category or 10% category).
You are correct. After delivery of the LE you discover that a new service is needed that was not disclosed on the LE. The cost of the service is $75. The service falls in the 10% tolerance category. If the original total of the 10% items was $1,000, then the additional $75 is equal to 7.5%. No violation exists since the amount on the CD is within the 10% tolerance limit.
Same for borrower requested changes, right? If a borrower request a change that causes the fees to increase, you can only reset tolerance if the fees increase beyond the applicable tolerance threshold (0% or 10%).
That is correct. Using the numbers in my previous reply, if this was a borrower requested change and the change represented 7.5% of the amount in the 10% bucket, then you could not reset tolerance, but at 7.5% there is no violation either.