BAP Blog Changes to the APR on Any Loan Must be re-disclosed now and there is a waiting period to close
Changes to the APR on Any Loan Must be re-disclosed now and there is a waiting period to close
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July 31, 2009, by

The Government has decided to issue out a new regulation that pertains to the APR and how we disclose.  Basically we are required to disclose several items to a borrower when they apply for a new loan which includes a GFE and a TIL which is what we do right now.  Good loan officers also re-disclose if anything changes within the loan such as rate, loan amount, or fees.  Well herein lies the changes – now the government is requiring a time period for review by the buyer before any loan can close and if ANYTHING changes the APR then we MUST re-disclose and another waiting period goes into effect.  Please read below and then I will go into a little more detail:
The change is constant mantra in our industry and it has really come to fruition this year.  I want to take a moment to clarify the new disclosure requirements.  It is imperative that Agents understand that these new rules will take effect with new applications on July 31st.  The following points are the crucial part of the process:
Disclosures completed and transmitted to borrower no later than 3 business days (including Saturdays) after loan application taken.
Loan can not close for 7 business days after disclosures are mailed or 3 business days if hand delivered to the borrower.
Evidence must be kept in the loan file of when disclosures were delivered.  Please note that certain assumptions are made.  Over night delivery is assumed that the documents are received the following business day.  Regular mail is presumed to be delivered 3 business days from date mailed.  If sending via e-mail you must use a read receipt and set up a secure delivery method such as password protected. The “read receipt” confirmation is what must be in file and then the file can close 7 days from that receipt confirmation.
If there is a change in terms that effect the APR by more than 0.125% on a fixed rate or an adjustable rate we must re-disclose and another 3 day waiting period must occur.  If there are changes that effect the APR less than these amounts you still must disclose but a waiting period is not necessary.  Fulton County- Atlanta Real estate will change because of this new regulation.  If you have any question or if you have feedback please list you comments on or site. 


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