[Anonymous]

Is it ok to issue a loan estimate if we have 5 of the 6 pieces of information or do we have to wait until we get the 6th piece to issue it? Income is the missing piece.
Thanks!

[rcooper]

You must deliver or place the LE in the mail the disclosures not later than the third business day after you receive consumer’s application (i.e. the six pieces of information you mentioned – consumer’s name, income, social security number to obtain a credit report, property address, estimated property value, and loan amount requested).

You may issue the LE prior to receiving all six pieces of this information; however, once you receive the final piece of information it is not considered a change of circumstance that would allow you to reset tolerances if any of the disclosed information is affected.

Comment 19(e)(3)(iv)(A)-3:
Six pieces of information presumed collected, but not required. Section 1026.19(e)(1)(iii) requires creditors to deliver the disclosures not later than the third business day after the creditor receives the consumer’s application, which consists of the six pieces of information identified in § 1026.2(a)(3)(ii). A creditor is not required to collect the consumer’s name, monthly income, social security number to obtain a credit report, the property address, an estimate of the value of the property, or the mortgage loan amount sought. However, for purposes of determining whether an estimate is provided in good faith under § 1026.19(e)(1)(i), a creditor is presumed to have collected these six pieces of information. For example, if a creditor provides the disclosures required by § 1026.19(e)(1)(i) prior to receiving the property address from the consumer, the creditor cannot subsequently claim that the receipt of the property address is a changed circumstance pursuant to § 1026.19(e)(3)(iv)(A) or (B).

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