Compliance – Change of Circumstance – Fees Disclosure: What are the timing requirements if a CD has been issued and a valid change of circumstance occurs? In our case a POA was added, which resulted in an increase of recording fees.
Answer: It can be disclosed on the CD even if the initial CD has gone out. The fee can be increased as long as it is re-disclosed no later than 3 days after finding out about the POA. Your example does not reset the 3-day clock for closing. The APR is not increasing more than [...]