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We are struggling to understand the application date due to definitions of the new TRID rules versus HMDA and Reg B. Some back ground on us to explain how we operate…..before Oct 3rd if we had an application with all the items except a property address we would go ahead and print all the early disclosures except for the GFE and PTIL and either have customer sign or mail out within the 3 days. Then once the property address was found the GFE and PTIL would be sent. For HMDA purposes we used the application date of the initial documents not the date GFE and PTIL were provided. We do not have a formal pre-approval or pre-qualification program either.
So if we had any of these TBD applications done prior to the 10/3 date, all of the new TRID guidance is saying we don’t have a completed application until after we received the property address and if that is after the 10/3 date then the new integrated disclosures are required, correct? I can understand that anything with a TBD that finds a property after the 10/3 date would need the new integrated disclosures but would we have to change our application date to that day?
Should we not be sending out any disclosures until we receive all six pieces of information?
We are concern with the application date to be used with HMDA, if we are to use the date of when we received property address instead of initial application request….we would have to redo the whole year for our HMDA reporting? Since we were using the initial application date prior to 10/3.
We are just struggling to make sure we are compliant with all 3 regs for the purpose of what is an application. Any input would be appreciated.
IMO if you report the loan as having requested preapproval you would issue a LE, and all related disclosures, based on the date you received the property address and use the original (pre 10/3) application date for HMDA reporting purposes. If you do not report the loan as having requested preapproval you would use the date you received the property address for both the TRID and HMDA application dates.
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