ABA Banking Journal
No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
SUBSCRIBE
ABA Banking Journal
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
No Result
View All Result
No Result
View All Result
Home Uncategorized

Compliance question of the month: Potential tolerance cure under TILA regarding mortgage disclosures

January 26, 2024
Reading Time: 1 min read

I have a question regarding a potential tolerance cure under Regulation Z (Truth in Lending Act) regarding mortgage disclosures. Under §1026.19(e)(3), charges disclosed on the loan estimate (LE) must be disclosed in good faith based on the best information reasonably available. An estimated cost is disclosed in good faith if the charge paid or imposed on the consumer does not exceed the amount actually paid or disclosed by a certain tolerance threshold on the closing disclosure (CD).

An appraisal fee of $550 was disclosed on the original LE in good faith. A subsequent invoice for the appraisal was received for $450 and a revised LE was sent for informational purposes. Before the CD was issued, a revised appraisal invoice was received for $550. The bank disclosed $550 as the appraisal fee on the CD.

Q May the bank rely on the fee disclosed on the initial LE ($550) instead of the amount disclosed on the revised LE ($450) when reviewing for a tolerance cure?

A Yes, the bank may rely on the amount disclosed on the initial LE.

While the question is not addressed in the regulation itself, the Bureau addressed it on page 50 in its TILA-RESPA Integrated Disclosure Rule small entity compliance guide.

“If a creditor decreases a charge on a revised loan estimate, closing disclosure, or corrected closing disclosure, the creditor is not required to use the decreased estimate for purposes of determining good faith, but instead may rely on the amount originally disclosed.”

For more information, contact ABA’s Rhonda Castaneda.
Please note that this section is not a substitute for professional legal advice.

Tags: Compliance
ShareTweetPin

Related Posts

Recent news from Treasury’s Office of Foreign Assets Control: April 5

Recent news from Treasury’s Office of Foreign Assets Control: March 30

Uncategorized
March 30, 2026

News items that are the most recent sanctions-related actions from the Office of Foreign Assets Control.

Recent news from Treasury’s Office of Foreign Assets Control: April 5

Recent news from Treasury’s Office of Foreign Assets Control: March 23

Uncategorized
March 23, 2026

News items that are the most recent sanctions-related actions from the Office of Foreign Assets Control.

Compliance question of the month: February 2025

Compliance question of the month: March 2026

Uncategorized
March 23, 2026

Compliance QOTM answers question on CRA public file.

Recent news from Treasury’s Office of Foreign Assets Control: April 5

Recent news from Treasury’s Office of Foreign Assets Control: March 16

Uncategorized
March 16, 2026

News items that are the most recent sanctions-related actions from the Office of Foreign Assets Control.

ABA Washington Summit begins today

ABA Washington Summit begins today

Uncategorized
March 9, 2026

More than 1,400 bank leaders from across the country are gathered in Washington, D.C. this week for the 2026 ABA Washington Summit. ABA will livestream the Tuesday and Wednesday general sessions on its X account, starting around 8:30...

Recent news from Treasury’s Office of Foreign Assets Control: April 5

Recent news from Treasury’s Office of Foreign Assets Control: March 9

Uncategorized
March 9, 2026

News items that are the most recent sanctions-related actions from the Office of Foreign Assets Control.

NEWSBYTES

FinCEN proposes rule to pay whistleblowers

March 30, 2026

Rep. Waters seeks details from Fed about Kraken decision

March 27, 2026

Consumer sentiment fell in March

March 27, 2026

SPONSORED CONTENT

How top agricultural lenders are approaching AI, automation and innovation in 2026

How top agricultural lenders are approaching AI, automation and innovation in 2026

March 2, 2026
Top 7 FP&A Trends in Banking for 2026

Top 7 FP&A Trends in Banking for 2026

March 1, 2026
How Instant Payments Can Accelerate B2B Payments Modernization

How Instant Payments Can Accelerate B2B Payments Modernization

February 3, 2026
Digital Banking: The Gateway to Customer Growth and Competitive Differentiation

Digital Banking: The Gateway to Customer Growth and Competitive Differentiation

February 1, 2026

PODCASTS

Podcast: Risk and strategy in sponsor banking

March 19, 2026

Podcast: From stablecoin to fraud, top takeaways from the 2026 ABA Summit

March 13, 2026

Podcast: How the SCAM Act would encourage platforms to go after scammers

February 4, 2026

American Bankers Association
1333 New Hampshire Ave NW
Washington, DC 20036
1-800-BANKERS (800-226-5377)
www.aba.com
About ABA
Privacy Policy
Contact ABA

ABA Banking Journal
About ABA Banking Journal
Media Kit
Advertising
Subscribe

© 2026 American Bankers Association. All rights reserved.

No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive

© 2026 American Bankers Association. All rights reserved.