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#1896332 - 02/12/14 04:11 PM Counseling notice / Property TBD
shea930 Offline
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Joined: Dec 2008
Posts: 267
If we had a customer apply for a loan to purchase a home on 12/6/2013 however didn't find a property until 1/16/2014. Would we have to provide the counseling list since the property was found after the 1/10/14 date even though they applied prior to that date? We are getting a kickback from our investor saying this should have been given.

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HOEPA and Homeowner Counseling Rule
#1896333 - 02/12/14 04:15 PM Re: Counseling notice / Property TBD shea930
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,228
Galveston, TX
Originally Posted By: shea930
We are getting a kickback from our investor saying this should have been given.


What difference does it make? Investors continually make their own rules. If you want to sell the loan to them, you have to follow them regardless of what any regulation might say.

The application was taken on 12/06/13 prior to the effective date of the new rules.
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#1896375 - 02/12/14 04:44 PM Re: Counseling notice / Property TBD shea930
John Burnett Offline
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John Burnett
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Posts: 40,086
Cape Cod
Under RESPA, the application wasn't received and the trigger pulled on the requirement for the list until the property address was supplied. The new rule applied on 1/16 when the application was actually received.
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John S. Burnett
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#1896511 - 02/12/14 07:06 PM Re: Counseling notice / Property TBD shea930
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,228
Galveston, TX
Oh yes, this is a RESPA requirement isn't it blush
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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