We often say you can’t take the requirements of one regulation and apply those to another regulation. A perfect example of this comes with the definition of an “application”. Regulation B says an application means an oral or written request for an extension of credit that is made in accordance with procedures used by a creditor for the type of credit requested. The term application does not include the use of an account or line of credit to obtain an amount of credit that is within a previously established credit limit. Regulation Z, on the other hand, says for purposes of TRID an application consists of the submission of the consumer's name, the consumer's income, the consumer's social security number to obtain a credit report, the property address, an estimate of the value of the property, and the mortgage loan amount sought. In other words, Regulation B has a much lower bar (oral or written request) for having an application than TRID does (six pieces of information).
Knowing at what point you have an application under each of these regulations is necessary to ensure compliance. For instance, obtaining joint intent is triggered by a Regulation B application while issuing a Loan Estimate is triggered by having a Regulation Z (TRID) application.
Jerod explains more about when you have a TRID application in the video.
Published
2024/04/12
