When it comes to compliance, the application date is often what triggers required disclosures. Problems can often arise because different regulations define an “application” differently. When you have a loan application that falls under the requirements of several different regulations, you have to be very careful. To demonstrate compliance with each regulation, you might have to document several different application dates. For example, Regulation Z says that you have a TRID application once you’ve received six specific pieces of information. Regulation B, on the other hand, says you have an application when you have an oral or written request for credit. Thus, if you use the TRID definition in providing Regulation B disclosures, those disclosures will often be made too late.
Jerod explains more in the video.
Published
2025/03/31