Skip to content
BOL Conferences
Thread Options
#1252142 - 09/17/09 04:55 PM Application date
gunches Offline
100 Club
Joined: Dec 2005
Posts: 210
I just received an application package yesterday from a loan officer. Application was to get a pre-approval for a purchase. It was dated and signed by the customer 7/20/09, address on property was on the application. Purchase agreement is dated 8/19/09, signed 8/24/09. He did early disclosures, dated them 7/23/09, but missed a lot of the fees, so I have to do them over again. Anybody have an idea what date to use on the correct disclosures. I always thought until you have a signed purchase agreement, you did not really have an application, but in this case, since the property address is on application, I'm drawing a blank

HELP

Return to Top
Lending Compliance
#1252146 - 09/17/09 04:58 PM Re: Application date gunches
mzachau, CRCM Offline
Gold Star
mzachau, CRCM
Joined: Oct 2006
Posts: 470
San Francisco
You have an application once your borrower has identified a property. since they had placed an address on the application, at that point IMHO I would say you have an application which would trigger your disclosure requirements.

If your redisclosing because your APR is out of tolerance and providing corrected disclosures you should use the date you create the disclosures. Your loan officer dated the disclosures 7/23/09, when did they receive the application (meaning was this a mail in or walk in, online, etc)?

Return to Top
#1252152 - 09/17/09 05:04 PM Re: Application date mzachau, CRCM
gunches Offline
100 Club
Joined: Dec 2005
Posts: 210
it was face to face - credit bureau was pulled 7/20/09, so I would assume application was received 7/20/09

Return to Top
#1252301 - 09/17/09 07:01 PM Re: Application date gunches
mzachau, CRCM Offline
Gold Star
mzachau, CRCM
Joined: Oct 2006
Posts: 470
San Francisco
I would date the disclosures the day you created them and document in the file. If any of the fees missed were FC's you would have to redisclose anyways.

Return to Top

Moderator:  Andy_Z