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We have provided an initial Closing Disclosure (CD) to the borrowers. We now have a change of circumstance (COC) so we have provided a new initial CD outlining the COC to the borrowers. We have provided this via e-sign. If we have multiple borrowers and only one borrower acknowledge receipt of the COC, does that suffice as receipt or do we need to mail to those that have not acknowledged? We already have acknowledgement of receipt for the first initial CD and a Final CD will be provided at closing.
To be clear, we are providing notices in the required time frames for ARM loans, our question above is specifically about non ARM variable rate loans.
I saw this on CMG yesterday and have to disagree as we were cited for this several years ago during an exam on one loan. It was the same situation and we reported income. The examiner referenced the same item “d” as above. It states “if the applicant or co-applicant is not a natural person…enter NA”, meaning either of them. Whereas for ethnicity & race you are reporting for each applicant, for income it is one field that is a total and if either is not a natural person it will therefore be reported as “NA” as referenced in item d.
That’s where I am going wrong. No, it does not meet the definition when I go to the commentary, it is “Other”. Thank you.
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.
