tag:blogger.com,1999:blog-2951729905080621137.post842485401723029921..comments2024-01-28T03:46:02.683-05:00Comments on Mortgage News Digest: TRID - It's Not Just a Disclosure, it's a ProcessThomas Morgan 202-550-LOANhttp://www.blogger.com/profile/03341328785507458855noreply@blogger.comBlogger2125tag:blogger.com,1999:blog-2951729905080621137.post-56312796125544576742014-12-17T13:08:22.861-05:002014-12-17T13:08:22.861-05:00Great comment. Turn this reading around: the loan ...Great comment. Turn this reading around: the loan officer CANNOT hold back the estimate as a result of not having information (as under GFE 2010 rules) beyond the 6 elements. The combination of TIL and RESPA means that a discussion of a specific loan amount will drive the generation of a Loan Estimate. The writers INTENDED to require early disclosure. This shouldn't change current process too much as the intent to proceed process and expiration of the Loan Estimate still exists.<br /><br />The downside is that the estimate may precede an ACTUAL application pursuant to the lender's credit policy, so the magnitude scope of the potential change of circumstance situation vastly increases. Instead of waiting until he or she has everything needed to issue an ACCURATE estimate, the estimate will change when the borrower provides additional information. Thomas Morgan 202-550-LOANhttps://www.blogger.com/profile/03341328785507458855noreply@blogger.comtag:blogger.com,1999:blog-2951729905080621137.post-57002828423502171252014-12-17T12:35:19.732-05:002014-12-17T12:35:19.732-05:00One of the large changes I am seeing in this new p...One of the large changes I am seeing in this new process is the loan officers ability to gather information (ie...bank statements, purchase contract, paystubs, etc.) from the client prior to the Loan Estimate being provided. For mortgage companies with a centralized disclosure desk this would pose an issue if you are taking a face to face interview of your client and in order for the loan officer to be compliant with these new rules they would need to wait for the Loan Estimate to be done before collecting any of the documents from the client. Am I correct in my understanding of 1026.19(e)(2)(iii)?Sherinoreply@blogger.com