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A mortgage amount is increased, may the bank issue the initial Closing Disclosure form?

A mortgage applicant at my bank requested an increase in her loan amount prior to closing. The bank granted her request, which resulted in an increase in fees. In completing Regulation Z’s (Truth in Lending Act) Closing Disclosure form, may the bank issue the initial Closing Disclosure form to reset the fee tolerances for this valid changed circumstance or must the bank reissue the Loan Estimate form, which may result in a delay in closing?

The bank may reset the tolerances in the initial Closing Disclosure form. See the Executive Summary of the 2018 TILA-RESPA Rule.

[I]f a changed circumstance or another triggering event has occurred, the 2018 TILA-RESPA Rule permits a creditor to reset tolerances with either an initial or corrected Closing Disclosure regardless of the number of days between consummation and the date the Closing Disclosure reflecting the revised estimate is required to be provided to the consumer. (July 2019)

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