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Is a Closing Disclosure Form necessary to report per-diem interest?

During a recent TILA-RESPA Integrated Disclosure (TRID) audit, the auditor criticized the bank for not providing a corrected Closing Disclosure form post-consummation. The only discrepancy was the amount of per-diem interest. Did the 2017 amendment provide some relief for this scenario?

Yes. The 2017 amendment updated the Commentary to provide that lenders are not required to provide a corrected Closing Disclosure form if the only changes are changes to per-diem interest and any disclosures affected by the changes in per-diem interest, even if the amount disclosed was different from the actual amount paid.

See comment 2 under Regulation Z §1026.19(f)(2)(iii)

Under §1026.19(f)(2)(iii)… A creditor is not required to provide corrected disclosures under § 1026.19(f)(2)(iii) if the only changes that would be required to be disclosed in the corrected disclosure are changes to per-diem interest and any disclosures affected by the change in per-diem interest, even if the amount of per-diem interest actually paid by the consumer differs from the amount disclosed.

(June 2019)

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