ok, we have been out of the mortgage business for so long I've forgotten everything I knew..and of course there have been all those reg. changes...
Management would like to roll-out a prequalification program for home loan purchases... based on information provided by the consumer then, the lender would provide a loan amount range or house sale price, that the customer may qualify for.... this information (loan amount range or selling price range) would be used as a shopping tool to ensure the houses they are looking at are in their ball-park. No credit report would be pulled, no property has been identified and it is based on information provided by interview with no attempts by lender to verify.
Therefore, even under new rules this is not an application, and is therefore not subject to RESPA or Reg. Z. and no early disclosures are required. CORRECT?
Given the same scenario even if we call it a pre-approval and issue something in writing (with all the typical disclaimers) it is still not an application subject to early disclosures even if we do order a credit report, process verifications of employment etc.and do not order appraisal & title (as no property identified) . CORRECT?
Are there any pitfalls,best practices, tracking sheets/logs or ??? that I should be considering. What about reg. B concerns, adverse action notices?