loan stamp

A financial institution (FI) is adding a closing fee to the Loan Estimate (LE) due to a valid changed circumstance. The loan is set to close early next week and the FI needs to issue the Closing Disclosure (CD) in order to close on the borrower’s timeframe. Can the FI send both the revised LE and the initial CD on the same day?

Answer: No. Under Regulation Z, there has to be one day between the LE and CD. A revised LE must be issued no later than four business days prior to consummation and a CD must be issued at least three business days prior to consummation. However, Regulation Z does also permit us to provide changes to fees due to a valid changed circumstance on the initial CD. (1026.19(e)(4)).

Do You Need Compliance Help?

We’re here to review your current compliance strategy and help you find A Better Way to manage risk.



Email for Non-Confidential Information Only

[email protected]

Office Location

2021 Midwest Road, Suite 200,
Oak Brook, IL 60523

Endorsed By