For those of you keeping up with the many changes and regulations that are impacting the real estate and lending environment, we can chalk one up for the home team! A clarification was made to Reg Z guideline that governed the redisclosure of loan docs if the APR was more than .125% different from originally disclosed. This used to include both an increase and a DECREASE in fees to the borrower. Now, Reg Z has been updated to reflect that only an INCREASE in fees will result in redisclosure. A decrease of .125% or more is no longer an issue.
Finally, logic is winning out.
Scott Cummins
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