On Monday, May 4, a creditor receives sufficient information establishing a qualifying changed circumstance: the property is two units rather than one, affecting permitted charges. It intends to use a revised Loan Estimate to reset the applicable good-faith baseline. It conducts substantially all business functions Monday through Friday, with no holiday. The Closing Disclosure has not been provided and consummation is sufficiently far away to meet the separate receipt deadline. By when must it provide the revised disclosure?
Correct Answer
D) Thursday 7 May, within 3 business days of learning the information
D. Thursday, May 7, is the third business day after Monday. Tuesday is day one, Wednesday day two and Thursday day three. The clock starts when sufficient information establishes the qualifying reason, not when a later internal review happens. Scope and exceptions: Only changes supported by an applicable revision reason may reset the relevant baseline. Separate restrictions govern receipt before consummation and revisions after provision of the Closing Disclosure. Source: Section 1026.19(e)(3)(iv), (e)(4)(i)–(ii) — https://www.consumerfinance.gov/rules-policy/regulations/1026/19/
Why This Is the Correct Answer
D. Thursday, May 7, is the third business day after Monday. Tuesday is day one, Wednesday day two and Thursday day three. The clock starts when sufficient information establishes the qualifying reason, not when a later internal review happens. Scope and exceptions: Only changes supported by an applicable revision reason may reset the relevant baseline. Separate restrictions govern receipt before consummation and revisions after provision of the Closing Disclosure.
Why the Other Options Are Wrong
Option A: Monday 11 May, within 5 business days of learning the information
Five business days exceeds this deadline.
Option B: At or before closing, provided the borrower signs an acknowledgement
A closing acknowledgment does not replace timely revision.
Option C: Wednesday 6 May, within 2 business days of learning the information
Wednesday is only the second day; it is earlier than the deadline.
Exam Tip
A permissible revision reason and compliance with timing are both necessary.
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