Banker's Compliance Consulting Blog

Documenting Intent to Proceed for TRID

Written by Jerod Moyer | Mar 12, 2026 8:13:36 PM

For applications subject to TRID, getting an applicant’s intent to proceed is an important step in the loan process. Prior to receiving the intent to proceed, an institution cannot charge the consumer for anything beyond “a bona fide and reasonable fee” for a credit report. The intent to proceed is essentially the date an applicant “accepts” the Loan Estimate and, as a result, the disclosed costs associated with the loan. A key piece of the requirements surrounding the intent to proceed process is documentation. While documenting an applicant’s intent to proceed is required, there is no mandated method for doing so. Thus, the documentation could look different from application to application, depending on how the intent to proceed was provided by the applicant. §1026.19(e)(2)(i)(A) states the …consumer may indicate an intent to proceed with a transaction in any manner the consumer chooses, unless a particular manner of communication is required by the creditor. The creditor must document this communication….

Jerod explains more in the video.

Published 2026/03/12