If you issue a GFE with a rate lock of 60 days, Line 1 is the end of the rate lock. Should Line 3 be 60 days, or the actual number of days left to go to settlement?

Line 3 reflects the number of days in your rate lock period.

(It is in parenthesis beside the block)

yes, that's what I thought, but the GFEs I am reviewing are less than the lock period, so I thought maybe I missed something. Thanks!

No, it doesn't have to be the number of days in your lock period.
FAQ p24 11) ...Line 3 in the "Important Dates" section on the GFE must be completed with one rate lock period and may need to take into account factors affecting the settlement date."

Here we use the rate lock expiration date minus 10 days.
That's to ensure the loan gets through the process and to the investor by the rate lock expiration date.

Here we go by what is printed on the GFE (your rate lock period) and we don't confuse our internal lock agreement dates with any rate agreement we may have with one of our secondary market investors. Part of our compliance check is to make sure the dates on the GFE actually match the dates on the rate lock agreement the customer executes.

Thankfully, we only have one expiration date to deal with.

Bottom line, Line 3 does not have to match the rate lock period.

How you can believe that when the GFE itself states that it is the number of days that correspond with the length of your rate lock period??

It's correct that line 3 doesn't necessarily match the 'true' lock period, but I'm with RF...it still (if locked) aligns with Line 1.

If your lock is 45 days, but you give them 40...then Line 1 goes out 40 and Line 3 states 40.

Plus HUD and various other webinars that spoke to this exact point.

eta: Point taken, Joker. I wasn't addressing anything about Line 1. Just whether Line 3 had to match your rate lock period.

We take your FAQ reference to mean that your rate lock period needs to extend to/past your projected settlement date...and how do you ignore the fact that the verbiage is pre-printed on the face of the GFE?

...yes, let's answer the original posters question....

Thanks everyone. After speaking with the mortgage dept mgr, they are doing what Truffle says - accounting for time to go to settlement. With the FAQ stating "account factors affecting the settlement date", I guess that is ok.

In reality, I think it is confusing to say, "your rate is available until July 20th (60 days), but you have to go to closing in 50 days (July 10th)" I understand why we are saying it, I just think it is a little confusing.

I don't agree with that, Slave. Your rate is only available for 50 days so that line should match what you have to back it up to.

You lock with the investor for 60 days, but to the customer it's 50.

eta: ooops...I already said the same thing last week...^^^!

Wait! I'm confused.

So if you have a 60 day lock, but you are going to take out 10 days to get them to closing on time, your Line 1 is going to be the calendar at 50 days (instead of 60) and line 3 will be 50 calendar days?

Do you have the borrower sign an actual form that indicates the rate is locked from this date to that date? If so, #1 better be the date of expiration on that form and #4 needs to be that number of day....don't know why anyone would interpret that any differently as you can always close prior to that date, say at the 50 day mark in your example.

Slave, look at it like this.

You have locked with your investor for 60 days. You need 10 days to deliver.

Therefore, the borrower has 'locked' for 50 days. That is the info for Line 1 and Line 3.

[we're saying the same thing, but in different ways].

Rules is saying use what you give the customer...and they are correct...if you need to back up 5 or 10, then the document they acknowledge needs to match that.

Another way to 'think it thru'

Say you haven't locked at all and Line 1 reflects date of application til 5pm.

Line 3 will show the rate lock info for the rate you are quoting at application (minus however many to get the loan delivered).

Line 4 will likely give that days to deliver number (in your example - 10)

OK, I pulled the file. I don't see anything signed by the customer but there is a print out with the lock information. In this instance, the lock expires 3/3/12. The GFE was produced on 1/4/12. Line 1 = 3/3/12. Line 3 = 55 days.

From 1/4/12-3/3/12(this is a Sat) = 59 days.
1/4/12 - 2/28/12 = 55 days

Is this GFE wrong then?

I'm really hung up on this and I am seeing it done different ways in different files, so I really need to be sure I understand this before I try to correct it.

In the example above, if it is a 60 day lock and we want 5 days to deliver- should the GFE have looked like this:

Line 1: 2/28/12
Line 3: 55 days

Even though the lock is really for 60 days which would go out to 3/4/12 (Sun)?