Your client is buying a home. At closing, they pull you aside and whisper that the documents they're being asked to sign don't match the Closing Disclosure - suddenly, there are thousands of dollars of new fees. Is this a red flag for predatory lending? Why or why not?
Under the TRID Rule (TILA-RESPA Integrated Disclosure), lenders must provide borrowers with a Closing Disclosure (CD) at least 3 business days before closing.
The numbers on the CD and closing documents must match (with very limited tolerance ranges).
Significant last-minute fee increases are a red flag for predatory lending or RESPA/TILA violations.
The client should not sign until discrepancies are resolved.
Reference (Virginia Real Estate & Federal Law):
TRID (12 CFR 1026.19(f))
Virginia Real Estate Principles -- Financing and Settlement section
A490-02REGS.pdf -- Loan closing requirements
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