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#1144210 - 03/12/09 06:49 PM Timing of AAN
Many Hats Offline
Platinum Poster
Joined: May 2008
Posts: 915
Orlando, FL
We received a mortgage application on 3/5/09.

Corect me if I am wrong, but, in orer to comply with reg B, we must notify the applicant of action taken within 30 days of receipt of application.

Okay, but in order to comply with RESPA, we are to provide initial disclosures within 3 days of receipt of a completed application.

So, if we were to send an ANN on 3/12, we would have complied with Reg B, but technically we violated Reg Z because we should have provided initial disclosures within 3 days.

Right?

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Lending Compliance
#1144226 - 03/12/09 07:00 PM Re: Timing of AAN Many Hats
M Cockrell Offline
Diamond Poster
M Cockrell
Joined: Jan 2003
Posts: 1,017
Dallas, TX
Originally Posted By: Many Hats
We received a mortgage application on 3/5/09.

Corect me if I am wrong, but, in orer to comply with reg B, we must notify the applicant of action taken within 30 days of receipt of [INSERT] a completed [INSERT] application.

Okay, but in order to comply with RESPA, we are to provide initial disclosures within 3 days of receipt of a completed [INSERT] an [INSERT] application [INSERT] (subject to applicant providing some specifics)[INSERT].

So, if we were to send an ANN on 3/12, we would have complied with Reg B, but technically we violated [INSERT] RESPA (HUD's Reg X) [INSERT] Reg Z because we should have provided initial disclosures within 3 days.

Right?
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"Remember no man is a failure who has friends." - Clarence (the Angel) Oddbody - It's a Wonderful Life

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#1144244 - 03/12/09 07:12 PM Re: Timing of AAN Many Hats
ktac MITCH Offline
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ktac MITCH
Joined: May 2005
Posts: 1,813
Giant side of TX
Originally Posted By: Many Hats
We received a mortgage application on 3/5/09.

Corect me if I am wrong, but, in orer to comply with reg B, we must notify the applicant of action taken within 30 days of receipt of application.

Okay, but in order to comply with RESPA, we are to provide initial disclosures within 3 days of receipt of a completed application.

So, if we were to send an ANN on 3/12, we would have complied with Reg B, but technically we violated Reg Z because we should have provided initial disclosures within 3 days.
Violations of both RESPA (not giving GFE, Servicing, booklet) & Reg Z (not giving early TIL) = assuming both RESPA and Reg Z applied
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