One of the most common questions we get regarding TRID has to do with when you can order certain loan-related services, such as an appraisal, pest inspection, etc. TRID says that you cannot ask an applicant to pay any fee, other than a credit report, until they give you an “intent to proceed” with the application. In other words, you are not prohibited from ordering loan services, you just can’t charge for them until you get an intent to proceed. You want to be careful because if, for example, you order an appraisal before you get an intent to proceed and the applicant decides to not pursue the loan, you cannot charge them for that appraisal per Regulation Z and you must still give them a copy of it per Regulation B.
Jerod explains more in the video.
Video Highlights:
- Banks can order services related to loan applications before receiving an Intent to Proceed.
- Once an applicant has expressed Intent to Proceed, they may then be billed for such services.
- If an appraisal is ordered before the Intent to Proceed, the free copy cannot be withheld until payment is made.
