[Christopher]

Seeking guidance on how to treat a preapproval (no property identified) issued in Sept 2015 where property is identified post TRID effective date. No TIL/GFE were provided in Sept. When property is known do I disclose pre-TRID (TIL/GFE) or post-TRID (LE)? The former seems correct if only because the latter would require resetting the application date, which would be a HMDA issue. However, if an “application” exists when all six elements are received, the sixth was received after the TRID effective date. Any help much appreciated.

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[kowsley]

I am of the opinion that you would handle this transaction the way you have in the past. You have a preapproval at this point, not a true application. You don’t have an application under TRID until you receive the property address. If that is received after the October 3rd implementation date then you would utilize the LE for disclosures.

[Christopher]

Kowsley, thanks. After further reading I agree. We are disclosing under TRID, but keeping the original date for HMDA reporting. A bit tricky for our LOS though.

[Author]

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