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9/26/2019

Mortgage Loans

Rainy day in NOLO by Caroline Gerardo ©


Is It Impossible to Get a Mortgage Loan? 
No it's POSSIBLE 
The Challenges:
Past credit crises, poor economies and resulting foreclosures caused mortgage loan guidelines to tighten. While some companies didn't survive, we're still here to continue helping those who can properly document their ability to qualify. And you might be surprised that it's not nearly as hard as some people would have you believe.
The Solutions:
Advance preparation and the right documentation will help streamline the process. 
Your Money: All necessary funds must be verified, and deposits must be documented.
Your Debts: Avoid delays. Don't open any new credit accounts. 
Your Income: We will confirm your income through pay stubs,  verification, tax returns, transcripts, etc. All new employment or variable income (such as bonus or commission) is subject to rules of history and continuance. Do not depend on this income until we discuss its acceptability.
Your Credit: If you're not already, you need to be extra mindful of managing your debts. To help protect your score:
  • Do not close old or unused accounts.
  • Do maintain high lines and low balance ratios.
  • Do not transfer balances to a brand new card (at least not before buying or refinancing).
  • Do not use your extra cash to pay off debt. Sometimes, it's better to have the cash than slightly lower balances. 
The most important thing to remember is that it's never too early to seek personalized advice. I work with mortgage loans every day, and I'm here to help you prepare so you can sail through the process when the opportunity is right. 
Financing is still abundantly available. It simply goes most easily to those who plan ahead.

Caroline Gerardo Barbeau please call me C. G.
phone: (949)784-9699
NMLS 324982

9/18/2019

California Residential Mortgage Lending Act









California Residential Mortgage Lending Act
 (CRMLA), enacted in 1994, became operative in 1996.  The law
is administered and enforced by the California Department of Business Oversight (DBO) under the direction of the
Commissioner of Business Oversight.  The chief executive officer of the California Department of Business Oversight
is the Commissioner.  Regulations are promulgated by the Department’s Commissioner.  
The CRMLA was enacted as an alternative to the existing laws licensing lenders under the California Financing Law
,
in order to provide mortgage bankers with a licensing law specifically directed at their primary functions of originating
and servicing residential mortgage loans.  
A
mortgage banker
 is a company, individual, or institution that originates purchases, makes, sells, or services loans
secured by mortgages on residential real property.  Mortgage bankers use their own funds, (or funds borrowed from a
warehouse lender) to fund mortgages.  
Makes residential mortgage loans
 means processing, underwriting, or as a lender using or advancing one's own
funds, or making a commitment to advance one's own funds, to a loan applicant for a residential mortgage loan.  [CA
Fin.Code §50003.(o)].  
cash, corporate capital, or warehouse credit lines at commercial banks, savings banks, savings and loan
associations, industrial loan companies, or other sources that are liability items on a lender's financial
statements, whether secured or unsecured, or 
2.  a lender's affiliate's cash, corporate capital, or warehouse credit lines at commercial banks or other sources
that are liability items on the affiliate's financial statements, whether secured or unsecured.  
Own funds
 does not include funds provided by a third party to fund a loan on condition that the third party will
subsequently purchase or accept an assignment of that loan.  [CA Fin.Code §50003.(t)].  
Residential real property
 (or real estate} is real property located in California that is improved by a one-
to-four family
dwelling.  [CA Fin.Code §50003.(v)].  
After a mortgage is originated, a mortgage banker might retain the mortgage in portfolio or sell the mortgage to an
investor.    Additionally,  after  a  mortgage  is  originated,  a  mortgage  banker  might  service  the  mortgage  or  sell  the
servicing  rights  to  a  mortgage  servicer.    The  distinguishing  feature  between  a  mortgage  banker  and  a  mortgage
broker  is  that  mortgage  bankers  close  mortgages  in  their  own  names,  using  their  own  funds,  whereas  mortgage
brokers facilitate originations for other financial institutions.  
Unlike the California Financing Law, the CRMLA is specifically designed to authorize and regulate mortgage-banking
activities.  A license can be issued as a residential mortgage lender, a residential mortgage loan servicer, or both
residential mortgage lender and residential mortgage loan servicer.
A
lender
 is someone who is an approved lender for the Federal Housing Administration, Veterans Administration,
Farmers  Home  Administration,  Ginnie  Mae,  Fannie  Mae,  or  Freddie  Mac.    A  lender  directly  makes  residential
mortgage loans and makes the credit decision in the loan transactions.  [CA Fin.Code §50003 (m)].
A
mortgage servicer
 or
residential mortgage loan servicer
 is someone who is an approved servicer for one of the
entities listed above and directly services or offers to service mortgage loans.  [CA Fin.Code §50003 (q)].
The  CRMLA  authorizes
Residential  Mortgage  Lender
  (CRML)  licensees  to  make
federally  related  mortgage
loans
, to make loans to finance the construction of a home, to sell the loans to institutional investors, and to service
such loans.  Licensees are authorized to purchase and sell federally related mortgage loans and to provide contract
underwriting services for institutional lenders.  Licensees are authorized to service any federally related mortgage loan
regardless of whether they make the loan or purchase a servicing portfolio.
A licensed CRMLA lender is also authorized to provide brokerage services to a borrower, by attempting to obtain a
mortgage loan on behalf of the borrower from an institutional lender.  
CRMLA Lenders must use Licensed MLOs
A CRMLA-licensed mortgage lender or servicer may not make or broker residential mortgage loans unless the loans
are negotiated by or applied for through licensed mortgage loan originators.
A CRMLA-licensed lender engaged in mortgage brokering activities must be sure that every mortgage loan originator
employed or compensated by that entity obtains and maintains a CRML mortgage loan originator license or has a
DRE MLO license endorsement.  
Any mortgage loan originator whose license or license endorsement has lapsed cannot work or broker loans for a
CRMLA-licensed lender.  [CA Fin.Code §50002.5. (a-c)].  
CRML MLOs must be Registered with the NMLS
Every  CRMLA-licensed  lender  engaged  in  the  business  of  making,  servicing,  or  making  and  servicing  residential
mortgage  loans  and  every  CRML-licensed  mortgage  loan  originator  must  shall  register  with  and  maintain  a  valid
unique identifier issued by the Nationwide Mortgage Licensing System and Registry.  [CA Fin.Code §50002.5 (d) and
10 CCR §1950.122.5 (a)].
When is a California Residential Mortgage Lending License
Required?
The CRMLA requires that any person engaged in the business of making or servicing residential mortgage loans
obtain a CRMLA license.  In general, any form of organization may get a license.  This includes natural persons, sole
proprietorships,  corporations,  partnerships,  limited  liability  companies,  associations,  trusts,  joint  ventures,
unincorporated  organizations,  joint  stock  companies,  governments,  political  subdivisions  of  governments,  and  any
other entity.  [CA Fin.Code §50002 (a)].
The CRML License requires that the company has a funding source or is in the process of obtaining a funding source
to fund their loans.  The CRML License is for companies that plan to fund mortgage loans, not just broker them. 
Therefore, companies must be financially able to fund mortgage loans with their own money, or have a warehouse
line of credit to fund the mortgage loans.
Exemptions to the Residential Mortgage Lending Act
Several entities, largely because they are already regulated by other laws and government agencies, are exempt from
CRMLA licensing requirements.  [CA Fin.Code §50002 (c)].
Entities Exempt from CRMLA Licensing Requirements
·
   Banks, trust companies, insurance companies, and industrial loan companies
·
   Federally chartered savings and loan associations, federal savings banks, and federal credit unions
·
   Savings and loan associations, savings banks, and credit unions authorized to conduct business in California
·
   Persons engaged solely in business, commercial, or agricultural mortgage lending
·
   Wholly owned service corporations of savings and loan associations or savings banks
·
   Federal, state and municipal governments
·
   Pension plans making residential mortgage loans to their participants
·
   Persons acting in a fiduciary capacity conferred by the authority of a court
·
   Licensed California real estate brokers
·
   California finance lenders licensed under the California Financing Law
·
   Trustees in a foreclosure proceeding.  [CA Fin.Code §50002]
Generally, a loan processor or underwriter, if certain other conditions are met, is exempt from obtaining a license.  [CA
Fin.Code §50003.6]
Based on the exemptions previously listed, a person or entity who is licensed under the CA  DRE
 as a real estate
broker or who has a CFL license does not have to obtain a CRML license to conduct residential mortgage activities.
Exempt from the CFL
Ÿ
   Banks, trust companies, savings and loan associations, insurance premium finance agencies, credit unions,
small business investment companies, community advantage lenders, California business and industrial
development corporations, or licensed pawnbrokers
.  
Ÿ
   A check casher who holds an appropriate permit but the exemption does not apply to transactions covered by
the California Deferred Transaction Law.  [CA Fin.Code §23000 et seq.] 
Ÿ
   A college or university making student loans.
Ÿ
   A broker-dealer.
Ÿ
   Any person who makes
5 or fewer
 commercial loans in a 12-month period, and the loans are incidental to the
business of the person relying upon the exemption.
Ÿ
   Any public corporation or other public entity, or agency when making a loan, so long as the public corporation,
public entity, or agency complies with all applicable federal and state laws and regulations.  
Ÿ
   Any nonprofit cooperative association for agricultural purposes.  
Ÿ
   Any corporation, association, syndicate, joint stock company, or partnership engaged exclusively in the
business of marketing agricultural, horticultural, viticultural, dairy, livestock, poultry, or bee products on a
cooperative nonprofit basis that loans or advances money to its membbers or in connection with those
businesses.
Ÿ
   Any corporation securing money or credit from any federal intermediate credit bank organized “Agricultural
Credits Act of 1923” that loans or advances money or credit so secured.
Ÿ
   A California Small Business Financial Development Corporation created pursuant to Corporations Code
§14000 et seq.  
Credit cards issued pursuant to a plan whereby the organization issuing the cards can acquire those
obligations that its members in good standing incur with those persons with whom the organization has
entered into written agreements setting forth the plan, and where the obligations are incurred pursuant to
those agreements; or whereby the organization issuing the cards can extend credit to its members. 
Additional conditions apply to this exemption.
Ÿ
   A bona fide conditional contract of sale involving personal property.  
Ÿ
   Premium financing as defined in CA Fin.Code 18563.  
Ÿ
   The California Infrastructure and Economic Development Bank.
Ÿ
   A licensed cemetery broker.
Ÿ
    A license to act as a broker under this division does not authorize the licensee to negotiate or perform any act
as a broker in connection with loans made or to be made by a lender not licensed as a finance lender under
this division.
Ÿ
   Any nonprofit church extension fund (provided certain requirements are met).
Ÿ
   A commercial bridge loan made by a venture capital company to an operating company (provided certain
requirements are met).
Ÿ
   A franchise loan made by a franchisor to a franchisee or a sub franchisor or by a sub franchisor to a
franchisee.  
Ÿ
   A program-related investment, a loan, guaranty, or investment made by a public charity, tax-exempt
organization (provided certain requirements are met). 
xempt Company Registration
Persons exempt from the CFL may apply to the DBO Commissioner for an
exempt company registration
 in order to
sponsor one or more individuals required to be licensed as mortgage loan originators pursuant to the federal Secure
and Fair Enforcement for Mortgaging Licensing Act (SAFE).
A mortgage loan originator who is an insurance producer eligible for a CFL license must originate mortgage loans
solely on behalf of the exempt person/company.  [CA Fin.Code §22065]
A mortgage loan originator who is an insurance producer eligible for licensure must meet all of the following
requirements:
Ÿ
   Be covered under an exclusive written contract with, and originate mortgage loans solely on behalf of, that
exempt person.
Ÿ
   Hold a current insurance producer license.  
Ÿ
   Have a current notice of appointment under Article 9 [commencing with Section 1702] of Chapter 5 of Part 2
of Division 1 of the Insurance Code from an insurer that controls, is controlled by, or is under common control
with that exempt person.
A  licensed  mortgage  loan  originator  who  is  an  insurance  producer  for  an  insurer  authorized  to  do  business  in
California  may  originate  loans  on  behalf  of  a  person  registered  under  CFL,  or  of  a  licensed  finance  lender  that
originates loans exclusively for a single person that is engaged in premium financing and exempt from CFL licensing. 
[See exemptions previously discussed.]

A finance lender, broker, or mortgage loan originator licensee can only have one place of business under a license. 
[CA Fin.Code §22152].  A finance lender, broker, or mortgage loan originator licensee can only transact business
under the name and at the place of business named in the license.  There are two exceptions.  First, if the borrower
requests that a loan be initiated or made at another location.  Second, if the licensee uses a webpage for solicitation,
initiation, and making loans.  [CA Fin.Code §22155.]
A  finance  lender  license,  broker  license,  and  the  license  of  every  employed  mortgage  loans  originator  must  be
conspicuously  displayed  at  the  authorized  place  of  business.    A  license  is  not  transferable  or  assignable.    [CA
Fin.Code §22151.]
A  licensee  must  notify  the  Department  of  a  change  of  address  at  least  ten  days  prior  to  the  move.    The  DBO
Commissioner has 10 days to notify the licensee  if the change is disapproved, otherwise  it is deemed approved. 
Failure to notify the DBO Commissioner can result in a penalty not to exceed $500.  [CA Fin.Code §22153.]
A finance lender, broker, or mortgage loan originator licensee can only have one place of business under a license. 
[CA Fin.Code §22152].  A finance lender, broker, or mortgage loan originator licensee can only transact business
under the name and at the place of business named in the license.  There are two exceptions.  First, if the borrower
requests that a loan be initiated or made at another location.  Second, if the licensee uses a webpage for solicitation,
initiation, and making loans.  [CA Fin.Code §22155.]
A  finance  lender  license,  broker  license,  and  the  license  of  every  employed  mortgage  loans  originator  must  be
conspicuously  displayed  at  the  authorized  place  of  business.    A  license  is  not  transferable  or  assignable.    [CA
Fin.Code §22151.]
On or before September 30th of each year, the Department notifies each licensee of the amount assessed and levied
against it and that amount must be paid by October 31st.  The minimum assessment is $250 per licensed location. 
Failure to pay the assessment can result in loss of the license.  [CA Fin.Code §22107.]

ential mortgage loans, based on the dollar amount of residential mortgage loans
originated  by  that  licensee  and  any  mortgage  loan  originators  employed  by  that  licensee.    Every  mortgage  loan
originator employed by the licensee must be covered by the surety bond.  [CA Fin.Code §22112.]
The minimum surety bond amount for a licensee who does not originate residential mortgage loans is $25,000.  The
surety bond amounts for a licensee who is engaged in residential mortgage loans is based on the aggregate dollar
amount of residential mortgage loans originated by the licensee in the preceding calendar year, as follows:
Aggregate Dollar Amount
Bond Amount
0
-
$1,000,000
$25,000
$1,000,001
-
$50,000,000
$50,000
$50,000,001
-
$500,000,000
$100,000
Over $500,000,001
$200,000




Net Worth Requirements
Each licensee must maintain a net worth of at least $25,000 at all times.  A licensed finance broker that employs one
or more mortgage loan originators and that arranges, but does not make, residential mortgage loans must maintain a
minimum net worth of at least $50,000.  A licensed finance lender and broker that employs one or more mortgage
loan originators and that makes residential mortgage loans must maintain a minimum net worth of at least $250,000. 
[CA Fin.Code §22104.]  These amounts are also displayed in the table below:
Licensee Activity
Net Worth Requirement
All licensees
$25,000
Broker/employs MLO/does not
make residential loans
$50,000
Lender and broker make
residential loans
$250,000
Each licensee is subject to a regulatory examination by the Department at any time even if no business has been
conducted.  “Examination”, in this context means a review of the licensee’s books and records, much like an audit. 
The licensee must pay the actual cost of the regulatory examination.  Failure to pay the cost of examination may
subject the licensee to administrative action including the revocation of the license.  [CA Fin.Code §§22701, 22707,
22714.] 

DBO Commissioner, through the Attorney General or a district attorney can have criminal proceedings
filed.  Conviction can result in a fine not to exceed $10,000 or imprisonment in county jail not to exceed one year, or
both.  [CA Fin.Code §§22753 & 22780.]
he DBO Commissioner may require licensees to maintain a file of all advertising copy for 2 years from the
date of its use.  The file must be available to the DBO Commissioner upon request.  [CA Fin.Code §22166.]
Ÿ
   A licensee must not advertise, in any way, a statement or representation that is false, misleading or
deceptive.  [CA Fin.Code §22161[b].]
Ÿ
   Blind ads are prohibited. 
Blind advertising
 is an advertisement used to solicit business that gives only a
telephone number, post office or newspaper box number, or name other than that of the licensee.  [10 CCR
1557.]
Ÿ
   If any advertisement refers to interest rates, charges, or cost of loans, those items must be stated fully and
clearly, and in a manner that the DBO Commissioner deems necessary to give adequate information to
prospective borrowers.  [CA Fin.Code §22164.]
alifornia Civil Code §§2924(a)(6) and 2924.17, the California Homeowner Bill of Rights applies only to
first lien, consumer purpose residential mortgage loans secured by a one-
to-four family residence that is occupied by
its owner/borrower.  The borrower must be a natural person who is the trustor under the deed of trust.  [CCC §§
2920.5, 2924.15.] 
The  Homeowner  Bill  of  Rights  places  the  burden  of  compliance  on  the
mortgage  servicer
,  i.e.,  the  person  who
services the loan or is responsible for interacting with the borrower, either as the current owner of the note or as the
owner’s agent.  [CCC §2920.5(a).] 


The Truth in Lending Act (TILA), 15 U.S.C.  1601 et seq., was enacted to promote the informed use of consumer
credit by requiring disclosures about financing terms and costs.  TILA, implemented by Regulation Z (12 CFR 1026),
became effective July 1, 1969.  The Real Estate Settlement Procedures Act (RESPA), 12 U.S.C.  2601 et seq., was
enacted to provide borrowers with pertinent and timely disclosures regarding the nature and costs of the real estate
settlement process
.  RESPA, implemented by Regulation X (12 CFR 1024), became effective June 20, 1975.
Cong
ress has amended TILA and RESPA significantly since they were enacted.  On December 31, 2013, the CFPB
published the
TILA
-RESPA  Integrated Disclosure  rule (TRID)
 implementing sections 1098(2) and 1100A(5) of the
Dodd-Frank Act, which direct
ed the CFPB to publish integrated disclosures for mortgage transactions under the Truth
in Lending Act (TILA) and sections 4 and 5 of RESPA.
The TRID rule created
integrated  disclosure  forms
 (Loan Estimate and Closing Disclosure) to be used for most
closed-end mortgage loan transactions.  The
Loan Estimate
 replaces the Good Faith Estimate (GFE) and the “early”
Truth-
in-Lending disclosure.  The Loan Estimate provides borrowers  with good-faith estimates of credit  costs and
transaction terms.  The
Closing Disclosure
 integrates and replaces the existing HUD-1 and the final TILA disclosure. 
For  loans  that  require  a  Loan  Estimate  and  that  go  to  closing,  lenders  must  provide  borrowers  with  the  Closing
Disclosure reflecting the actual terms of the transaction.  The Loan Estimate and Closing Disclosure are discussed in
Regulation Z sections 1026.37 and 1026.38.
he TRID rule applies to most closed-end residential mortgages.  Additionally, the integrated disclosure requirements
apply to construction-only loans and to loans secured by vacant land or by 25 or more acre, all of which are currently
exempt  from  RESPA  coverage.    [12  CFR  §1026.19(e)].    Most  closed-end  mortgage  loans  are  exempt  from  the
requirement to provide the GFE, HUD-1, and servicing disclosure requirements of RESPA under Regulation X. 
[12
CFR §1024.6, §1024.7, §1024.8, §1024.10, and §1024.33(a)].  Instead, these loans are subject to disclosure, timing,
and other requirements under the TRID rule.
The integrated disclosures are not used to disclose information about reverse mortgages, home equity lines of credit
(HELOCs), mobile homes or by a dwelling that is not attached to real property, or other transactions not covered by
the TRID rule.  The TRID rule also does not apply to loans made by a person who is not a
creditor
 as defined by
Regulation  Z  (e.g.,  a  person  who  makes  5  or  fewer  mortgages  in  a  year).    Creditors  originating  these  types  of
mortgages must continue to use, as applicable, the GFE, HUD-1, and TIL disclosures.
NOTE: A creditor may not use the TILA-RESPA Integrated Disclosure forms instead of the GFE, HUD-1, and TIL
forms for transactions that continue to be covered by TILA or RESPA that require those disclosures (e.g., reverse
mortgages).
Use TILA-RESPA Integrated Disclosures
Most closed-end mortgage loans, including: 
o
   Construction-only loans 
o
   Loans secured by vacant land or by 25 or more acres 
Continue to use existing TIL and RESPA disclosures (as applicable)
HELOCs (subject to disclosure requirements under 12 CFR 1026.40) 
Reverse mortgages (An open-end reverse mortgage receives open-end disclosures, not a GFE or HUD-1. 
) 
Chattel-secured mortgages (i.e., mortgages secured by a mobile home or by a dwelling that is not attached to
real property, such as land) (subject to existing TIL disclosures, and not RESPA) 
The Truth in Lending Act (TILA), 15 U.S.C.  1601 et seq., was enacted to promote the informed use of consumer
credit by requiring disclosures about financing terms and costs.  TILA, implemented by Regulation Z (12 CFR 1026),
became effective July 1, 1969.  The Real Estate Settlement Procedures Act (RESPA), 12 U.S.C.  2601 et seq., was
enacted to provide borrowers with pertinent and timely disclosures regarding the nature and costs of the real estate
settlement process
.  RESPA, implemented by Regulation X (12 CFR 1024), became effective June 20, 1975.
Cong
ress has amended TILA and RESPA significantly since they were enacted.  On December 31, 2013, the CFPB
published the
TILA
-RESPA  Integrated Disclosure  rule (TRID)
 implementing sections 1098(2) and 1100A(5) of the
Dodd-Frank Act, which direct
ed the CFPB to publish integrated disclosures for mortgage transactions under the Truth
in Lending Act (TILA) and sections 4 and 5 of RESPA.
The TRID rule created
integrated  disclosure  forms
 (Loan Estimate and Closing Disclosure) to be used for most
closed-end mortgage loan transactions.  The
Loan Estimate
 replaces the Good Faith Estimate (GFE) and the “early”
Truth-
in-Lending disclosure.  The Loan Estimate provides borrowers  with good-faith estimates of credit  costs and
transaction terms.  The
Closing Disclosure
 integrates and replaces the existing HUD-1 and the final TILA disclosure. 
For  loans  that  require  a  Loan  Estimate  and  that  go  to  closing,  lenders  must  provide  borrowers  with  the  Closing
Disclosure reflecting the actual terms of the transaction.  The Loan Estimate and Closing Disclosure are discussed in
Regulation Z sections 1026.37 and 1026.38.
The TRID rule applies to most closed-end residential mortgages.  Additionally, the integrated disclosure requirements
apply to construction-only loans and to loans secured by vacant land or by 25 or more acre, all of which are currently
exempt  from  RESPA  coverage.    [12  CFR  §1026.19(e)].    Most  closed-end  mortgage  loans  are  exempt  from  the
requirement to provide the GFE, HUD-1, and servicing disclosure requirements of RESPA under Regulation X. 
[12
CFR §1024.6, §1024.7, §1024.8, §1024.10, and §1024.33(a)].  Instead, these loans are subject to disclosure, timing,
and other requirements under the TRID rule.
The integrated disclosures are not used to disclose information about reverse mortgages, home equity lines of credit
(HELOCs), mobile homes or by a dwelling that is not attached to real property, or other transactions not covered by
the TRID rule.  The TRID rule also does not apply to loans made by a person who is not a
creditor
 as defined by
Regulation  Z  (e.g.,  a  person  who  makes  5  or  fewer  mortgages  in  a  year).    Creditors  originating  these  types  of
mortgages must continue to use, as applicable, the GFE, HUD-1, and TIL disclosures.
NOTE: A creditor may not use the TILA-RESPA Integrated Disclosure forms instead of the GFE, HUD-1, and TIL
forms for transactions that continue to be covered by TILA or RESPA that require those disclosures (e.g., reverse
mortgages).
or closed-end credit transactions secured by real property (other than reverse mortgages), the lender is required to
provide the borrowers with good-faith estimates of credit costs and transaction terms on the Loan Estimate.  [12 CFR
1026.19(e)].
Requirements for Loan Estimates
Loan Estimate must be in writing.
Loan Estimate must contain a good faith estimate of credit costs and transaction terms.
The lender must deliver the Loan Estimate or place it in the mail no later than the third business day after
receiving the application.
If a mortgage broker receives a borrower’s application, either the lender or the mortgage broker may provide
the Loan Estima
te.   A lender can rely on a mortgage broker to deliver the Loan Estimate; but the lender
remains responsible for its accuracy.
Lenders generally may not issue revisions to Loan Estimates because they later discover technical errors,
miscalculations, or underestimations of charges
.  Lenders can issue revised Loan Estimates only in certain
situations such as when changed circumstances result in increased charges.
Circumstances result in increased charges.