A loan application date triggers a variety of compliance requirements and getting it right is very important. While that seems like it would be easy to do, we find that often isn’t the case. Regulation B (ECOA), Regulation C (HMDA), and TRID each have their own definitions of “application”. For example, under Regulation B, you have an application when you have a request for credit. Under Regulation C, you need a request for credit and a property address. For TRID, you have an application when you receive six pieces of required information (name, income, SSN, property address, property value estimate, and loan amount). Thus, it’s quite possible to have three different “application” dates for the same loan application! You need to make sure you are using the correct date for whichever compliance requirements you’re working with.
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Published
2018/02/21
Deb Irving