New York Implicit Bias Awareness

Note that the creditor or lender is required to deliver or place in the mail the Loan Estimate no later than seven business days before consummation of the transaction.

The instructors suggest that you open and/or print the sample closing disclosure form to have as we walk through each of the pages.

Once the Closing Disclosure is delivered, the lender can no longer change the Loan Estimate Form. If changes to the Loan Estimate Form are required, and the lender re-delivers a new LE to the borrower, all of the delivery and receipt timelines start over.

An example might be if the loan product changes a week before closing, and a new LE is issued by the lender via first class mail, then delivery and receipt will take up to six days. With a 3 day window still necessary for delivery and receipt of the Closing Disclosure, the closing date will likely need to be moved.

Items disclosed as Services the Borrower Did Shop For and Services the Borrower Did Not Shop For are re-alphabetized when an item is added to or removed from the Closing Disclosure, when compared to the Loan Estimate. This may make cross-referencing charges between disclosures a little annoying.

This is a slight communication change that should not cause problems, but is required to comply with Regulation Z. We list it here for information purposes in case the question does come up.

Fannie Mae and Freddie Mac are not considered “federal agencies” under the False Claims Act, but rather non-governmental third parties in particular circumstances, including spending money on the government’s behalf. This determination was held by the U.S. Court of Appeals and can be derived to encompass all GSEs.