When do you have an application for credit? That may seem like a fairly simple question but in reality, it’s not. That’s because there is no one universal definition of an “application” for compliance purposes. You have to look at each regulation, how it defines an application and proceed accordingly. While many financial institutions try, you just can’t simplify it. For example, in a typical mortgage transaction, Regulation B, HMDA and TRID could all come into play, and all three have different definitions as to what constitutes an application. Receipt of an application triggers certain compliance requirements and if you use the TRID definition for Regulation B requirements or the HMDA definition for the TRID requirements it will likely result in violations.
David explains more in the video.
Published
2024/10/21