In a file escalation meeting, the branch manager sees facts tied to TILA RESPA Loan Estimate Tolerances. What should the file reflect?
Correct Answer
D) Place the fee in the correct tolerance category
Why this is correct: Under TRID, fees on the Loan Estimate are placed into one of three tolerance categories (0%, 10%, or unlimited). The category determines how much the actual closing cost can increase. Correctly categorizing a fee is fundamental because it dictates whether a variance is permitted, requires a refund, or needs a corrected disclosure. This directly follows the original explanation on TRID fee disclosures and tolerance categories. Why the other choices are wrong: "Treat a changed provider fee as unlimited solely because it is paid to a third party" is wrong because while some third-party fees can be in the unlimited category (if the borrower selects the provider), they are not automatically unlimited; the category depends on specific selection and timing rules. "Leave the Loan Estimate unchanged after the creditor learns the disclosed charge is inaccurate" is wrong because if a charge becomes inaccurate, a revised Loan Estimate may be required under valid change of circumstance rules; leaving it unchanged can lead to tolerance violations. "Cure a tolerance problem by renaming the fee instead of documenting or refunding the variance" is wrong because mischaracterizing a fee to avoid a tolerance violation is deceptive and does not cure the underlying compliance failure; the proper cure is a refund or a valid redisclosure. Exam tip: Memorize the three tolerance buckets: 0% (services borrower cannot shop for), 10% (total of services borrower can shop for), and unlimited (borrower-selected services from an unaffiliated provider).
Why This Is the Correct Answer
The correct response is "Place the fee in the correct tolerance category" because TRID fee disclosures and tolerance categories govern estimates, revisions, and closing-cost comparison.
Why the Other Options Are Wrong
Option A: Treat a changed provider fee as unlimited solely because it is paid to a third party.
This choice is a tempting shortcut, but it conflicts with fee disclosure and tolerance treatment because the file still needs the required documentation, timing, or rule-based review before the action is taken.
Option B: Leave the Loan Estimate unchanged after the creditor learns the disclosed charge is inaccurate.
This choice is not the best answer because it applies the wrong file step for fee disclosure and tolerance treatment; the governing rule is tested by the correct option.
Option C: Cure a tolerance problem by renaming the fee instead of documenting or refunding the variance.
This choice is a tempting shortcut, but it conflicts with fee disclosure and tolerance treatment because the file still needs the required documentation, timing, or rule-based review before the action is taken.
Memory Technique
TILA RESPA Loan Estimate Tolerances: identify the rule being tested, then choose the action that documents or applies that rule before the file moves forward.
Exam Tip
For fee disclosure and tolerance treatment questions, separate the required file step from plausible sales, timing, or documentation shortcuts.
Common Mistakes to Avoid
- -Choosing an internal exception instead of the governing rule
- -Treating preliminary or informal facts as a substitute for required documentation
- -Answering from a familiar but unrelated mortgage topic
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