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.
Published
2024/05/06