While it appears we will have a delay until October 3rd (Please note there has been a comment period before official delay). Nevertheless, I want to continue to reinforce some of the rules before that time.
1. Original interpretation was that a new closing disclosure would have to be issued when APR changed up or down; however it has been clarified to only be an increase in the APR. At this point, the only time a new closing disclosure and new three day will... occur is (1) APR increases by 1/4% or 1/8% depending on loan (2) Addition of pre-payment penalty (3) change of loan product.
2. Receiving Closing Disclosure may not necessarily mean a clear to close for closing. There is a possibility that a closing disclosure is issued, but lender does not issue closing package for closing due to subsequent underwriting. At this point issuance of closing disclosure is more of a bank origination form rather than closing form.