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Three days before a scheduled Friday closing, the lender discovers that the APR has increased by more than 1/8 of 1 percent due to a last-minute change in loan fees. The Closing Disclosure was already delivered to the borrower on Monday. What action must the lender take?

Federal Mortgage Law · 24% of the SAFE examhard

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Correct answer: Issue a corrected Closing Disclosure and begin a new three-business-day waiting period before consummation can occur

Under TRID (Regulation Z), three specific events trigger a new three-business-day waiting period after a corrected Closing Disclosure is issued: (1) the APR increases by more than 1/8 of 1 percent (0.125%) for fixed-rate loans or 1/4 of 1 percent (0.25%) for adjustable-rate loans; (2) the loan product changes; or (3) a prepayment penalty is added. Here, the APR increased by more than 1/8%, which triggers a new waiting period and prevents the Friday closing from proceeding as scheduled. "Issue a corrected Closing Disclosure but closing may..." is incorrect—the 1/8% threshold for fixed-rate loans has been exceeded. "Issue a corrected Closing Disclosure and begin a new..." confuses the 1/4% threshold, which applies to adjustable-rate loans only. "Proceed with Friday closing because the CD was deliv..." is prohibited; verbal notice does not substitute for written disclosure and does not cure the waiting period requirement.

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