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Redisclosing TIL

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  • #2470
    frisbie
    Participant

    I have a situation where the APR is out of guidelines with the index rate plus the 1.5, the only fee we have that affects the APR is our origination fee and it is in the 0% tolerance section of the GFE, can we redisclose and lower that fee to lower our APR? As long as we do it three days before closing.

    #2785
    jholzknecht
    Keymaster

    I am a little confused by your question, but since I have been spending so much time with 1,400 pages of proposed Regulation Z I am getting confused about everything.

    If appears you want to avoid having a first lien higher-priced mortgage, which occurs when your APR exceeds the APOR by 1.5 or more percentage points. In your situation you could assure the APR stays below the threshold either by lowering the origination charge or lowering your rate. If you lower the APR, by either method, you would need to re-disclose if the APR changes by more than the allowed tolerance. It is doubtful that you would have a tolerance problem. But, if you do need to redisclose, you must delay closing until three business days after the consumer receives the revised disclosure.

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