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A compliance review finds that a valid changed circumstance raises a fee before the Closing Disclosure has been issued. What should the MLO do next?

Correct Answer

B) Issue a revised Loan Estimate within three business days

Lines 198-203; 12 CFR 1026.19(e)(3)(iv) and 1026.19(e)(4)(i). A valid changed circumstance permits a revised Loan Estimate, but the timing window is still three business days after sufficient information is received. Therefore, the correct response is "Issue a revised Loan Estimate within three business days".

Answer Options
A
Ignore the issue if the borrower orally agrees to continue.
B
Issue a revised Loan Estimate within three business days
C
Proceed based only on borrower preference and document the file later.
D
Rely on sales practice rather than required verification, disclosure, or documentation.

Why This Is the Correct Answer

Lines 198-203; 12 CFR 1026.19(e)(3)(iv) and 1026.19(e)(4)(i). A valid changed circumstance permits a revised Loan Estimate, but the timing window is still three business days after sufficient information is received. Therefore, the correct response is "Issue a revised Loan Estimate within three business days".

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