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Three Days Starting From When?
by Dan Persfull, BOL Guru
Guru BIOS
Question: We have a RESPA question. The rule states that the Good Faith Estimate is to be provided no later than three business days after the application is received. We are looking for clarification on how received is defined. Is it considered received the date the bank received the application or the date the applicant's lender received the application?
For example: An applicant contacts a lender at our bank to apply for a mortgage. Our lender mails out an application to the applicant. The applicant completes the application and delivers the application to the bank on a day that the the lender is not here. The applicant's lender will be gone for the another 4 days. Since the bank received the application but not the actual lender, when does the 3 days start? If we held the application for the applicant's lender, can we indicate the date received as the date the lender received it vs. the date the bank received it?
Answer: If you do a search on "application date" you'll find several threads discussing the issue.
The application is received when the institution receives it.
For further reference look at the definition of Lender in 3500.2. Lender refers to the institution, not the loan officer .
First published on BankersOnline.com 9/19/05
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