TRID Applications & Strategic Collection

When it comes to mortgage lending, the definition of an “application” can differ depending on what Regulation you’re talking about (Regulation B, Regulation Z, HMDA, etc.). It’s important to know the differences because each Regulation has certain requirements that are triggered once you receive an application. For TRID purposes, Regulation Z says that once a lender receives six specific pieces of information (name, income, SSN, property address, property value estimate, loan amount), they have an application which then triggers the Loan Estimate. However, the TRID requirements also have a provision that allows for “strategic collection”.

This means that you can purposely not ask the applicant for one or more of those six pieces of information, so you don’t have an application and therefore buy more time before you have to provide a Loan Estimate. But you need to be careful, because if the applicant offers the information you can’t refuse it either.

Jerod explains more in the video.

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Jerod Moyer

Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru. Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports-related!

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