[Christopher]

Thanks Robin. Our issue is that our LOS vendor is providing only one version of the CD based on the loan Purpose. When the transaction is not a purchase the version provided is model form H24-E that doesn’t include section L Paid Already by or on Behalf of Borrower at Closing. Is there somewhere else in H24-E where the disclosure can be made?

[Christopher]

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.

[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.

[Christopher]

Thanks for reply, I should have included in my post that the PIC is a wholly owned subsidiary of the bank.

[Christopher]

Susan – Thanks, my contact is cstrauss@cmsbk.com. Appreciate your help. Regards, Chris

[Author]

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