Hope this clears some confusion -
Under the final rule, receipt of an “application” triggers a creditor's obligation to provide the Loan Estimate within three business days.
This is true whether the loan app is taken by phone or in person.
The new Loan Estimate is for all loan apps taken on or after Oct 3rd. Any app taken before Oct 3rd must use the old GFE and Initial TIL.
Filling out a loan app is not necessarily ‘completing’ a loan app. There are six items required for an app to be considered complete, thus triggering the 3 days max period before an initial LE is disclosed.
Required Information to trigger a Loan Estimate:
1. The consumer's name
2. The consumer's income
3. The consumer's Social Security number to obtain a credit report (or other unique identifier if the consumer has no Social Security number)
4. The property address
5, An estimate of the value of the property
6. The mortgage loan amount sought
The creditor is required to provide the borrower with an official Loan Estimate within three business days of receiving the sixth pieces of information, regardless of other information that will be collected.
It's not surprising to see the old disclosures getting the same treatment as the new although the timing and delivery methods remained the same. Creditors are being very conservative right now.
http://www.cfpbmonitor.com/2014/08/28/cfpb-answers-faq-on-the-tila-respa-integrated-disclosures-rule/
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