New property information that could not reasonably have been known when the Loan Estimate was issued directly increases a required, non-shoppable title-service fee by $340. The creditor has sufficient evidence of the change, has not issued the Closing Disclosure, and can meet the revised Loan Estimate receipt deadline. To use the justified increase as a revised baseline, what should the creditor do?
Correct Answer
D) Provide the revised estimate within three business days after receiving sufficient information
D. Provide the timely revision supported by the documented change. The revised facts establish a qualifying event, an affected fee and enough information to support it. Only the increase caused by that event is supported; the event does not reopen unrelated charges. Scope and exceptions: A revised Loan Estimate cannot be issued on or after the Closing Disclosure date, and its receipt cutoff also applies. Ten-percent-category charges need a separate aggregate analysis. Source: 1026.19(e)(3)(iv)(A), (e)(4)(i)–(ii); comment 19(e)(3)(iv)-2 — https://www.consumerfinance.gov/rules-policy/regulations/1026/19/
Why This Is the Correct Answer
D. Provide the timely revision supported by the documented change. The revised facts establish a qualifying event, an affected fee and enough information to support it. Only the increase caused by that event is supported; the event does not reopen unrelated charges. Scope and exceptions: A revised Loan Estimate cannot be issued on or after the Closing Disclosure date, and its receipt cutoff also applies. Ten-percent-category charges need a separate aggregate analysis.
Why the Other Options Are Wrong
Option A: Not a changed circumstance, as title fees are the lender's own estimate
The facts establish a relevant third-party cost change.
Option B: A valid changed circumstance, but the revision waits until the closing
Waiting until closing ignores the stated timing requirement.
Option C: Not a changed circumstance unless the increase exceeds 10% of the whole fee
This non-shoppable fee is not governed by a 10% aggregate trigger.
Exam Tip
Match the event, affected charge and disclosure stage.
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