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#1289146 - 11/18/09 08:14 PM 3-day initial disclosure
Random Offline
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Joined: Jun 2008
Posts: 287
For applicable loans GFE and initial TIL are to be provided within 3 days of application. If you do not have a property address do you still issue the early disclosures?

Application is defined as:

Application means the submission of a borrower's financial information in anticipation of a credit decision relating to a federally related mortgage loan, which shall include the borrower's name, the borrower's monthly income, the borrower's social security number to obtain a credit report, the property address, an estimate of the value of the property, the mortgage loan amount sought, and any other information deemed necessary by the loan originator. An application may either be in writing or electronically submitted, including a written record of an oral application.

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Lending Compliance
#1289167 - 11/18/09 08:23 PM Re: 3-day initial disclosure Random
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
I read the application definition to mean that if you don't have a property address, you don't have an application. Therefore the timing provision doesn't 'kick in' until you have at least all six pieces of required information.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1289317 - 11/18/09 10:10 PM Re: 3-day initial disclosure Doug Hendrickson
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,333
ETIL doesn't apply unless RESPA applies, so no.
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