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#1761582 - 11/28/12 04:00 PM Big Bank Doesn't Provide Early Disclosures
Norman Paperman Offline
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I'm hoping some of you can help me understand how this works.

I am refinancing my personal mortgage and decided, just for fun, to get a quote from an unnamed Big Bank. I applied online on Friday(Full RESPA application). Having not heard anything, I called Big Bank. I spoke with a "Mortgage Consultant". I asked him if I should be expecting a GFE/Early TIL, etc. in a few days to use for shopping. He told me that submitting "information" online doesn't mean he has to provide a GFE. He said that it's not an application until after we speak and determine a product.

I don't recall seeing loan product as being a requirement for RESPA.

Thoughts?
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RESPA
#1761597 - 11/28/12 04:09 PM Re: Big Bank Doesn't Provide Early Disclosures Norman Paperman
Matt_B Offline
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A CU, Where Regs Don't Apply
From: http://www.bankersonline.com/articles/v07n02/v07n02a2.html

Quote:
Regulation Z and RESPA have much in common when it comes to defining an application. These regulations require disclosures that explain the terms of the loan being applied for. In order for the disclosures to contain useful information, they must be based on the terms of the loan. The lender knows this much later that the point at which Regulation B defines application.

RESPA's Regulation X defines application to include both a property address and the filing of financial information with the creditor. The submission of financial information must also be in anticipation of a credit decision. Although this is somewhat of a back door approach to defining application, it places appropriate emphasis on the fact that both creditor and applicant have put forward enough information to prepare disclosures.
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#1761672 - 11/28/12 05:09 PM Re: Big Bank Doesn't Provide Early Disclosures Norman Paperman
Happy Birthday Kathleen O. Blanchard Offline

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Originally Posted By: Garret01
I'm hoping some of you can help me understand how this works.

I am refinancing my personal mortgage and decided, just for fun, to get a quote from an unnamed Big Bank. I applied online on Friday(Full RESPA application). Having not heard anything, I called Big Bank. I spoke with a "Mortgage Consultant". I asked him if I should be expecting a GFE/Early TIL, etc. in a few days to use for shopping. He told me that submitting "information" online doesn't mean he has to provide a GFE. He said that it's not an application until after we speak and determine a product.

I don't recall seeing loan product as being a requirement for RESPA.

Thoughts?

If the online ap didn't provide what they need to provide a useful GFE, I would think the bank would contact you to move forward, not wait for applicants to contact them.
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#1761681 - 11/28/12 05:18 PM Re: Big Bank Doesn't Provide Early Disclosures Matt_B
Norman Paperman Offline
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I still don't get it. Full RESPA application. Including requested term/rate/amount. What else would you need? Can they use the seventh RESPA item "...and anything else the lender might require..."?

Can I tell my lenders to not worry about providing early disclosures until a phone call happens? Something is missing. Perhaps it is as simple as "Big Bank".
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#1761687 - 11/28/12 05:21 PM Re: Big Bank Doesn't Provide Early Disclosures Norman Paperman
Dan Persfull Offline
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If it were me I would be filing a complaint with the CFPB giving the bank's name and also the associates name I spoke with.
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#1761689 - 11/28/12 05:22 PM Re: Big Bank Doesn't Provide Early Disclosures Norman Paperman
Truffle Royale Offline

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Try calling the big bank again and talking to someone other than the 'mortgage consultant'. You could even ask for their compliance officer/department. See what kind of answer you get from them after you tell them that the term, rate and amount were all on your online submission. I'm betting you get a different response.

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#1761695 - 11/28/12 05:30 PM Re: Big Bank Doesn't Provide Early Disclosures Norman Paperman
Happy Birthday Kathleen O. Blanchard Offline

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Based on what you supplied, sounds like that was enough. I would call a supervisor. Sounds like perhaps a lazy employee not following up.

Odd that they don't have GFEs centralized and leave themselves at risk of individual employees messing up.
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#1761697 - 11/28/12 05:33 PM Re: Big Bank Doesn't Provide Early Disclosures Norman Paperman
swiggles Offline
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The 9 billion dollar bank that acquired my former bank, surprisingly doesn't have much of anything centralized.....don't know how they keep things straight and stay out of trouble. My former bank was about 3 billion....we had nearly everything centralized. So those poor employees still left there are having to take a step back in time....like..........years back.
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#1761717 - 11/28/12 05:48 PM Re: Big Bank Doesn't Provide Early Disclosures Norman Paperman
Norman Paperman Offline
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I'll give them the benefit of doubt and see if I have anything show up in the mail.



Let's just say that this is one of the five largest banks in the USA

Glad I'm not crazy. I don't see how they wouldn't get tagged if this were a systemic issue.
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#1761771 - 11/28/12 06:39 PM Re: Big Bank Doesn't Provide Early Disclosures Norman Paperman
rlcarey Offline
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Just be glad you don't have any rogue mortgage consultants or loan officers that don't follow the book and make their own rules in your bank smile That never happens in smaller banks.......
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#1761777 - 11/28/12 06:43 PM Re: Big Bank Doesn't Provide Early Disclosures rlcarey
RR Joker Offline
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laugh
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#1762299 - 11/29/12 05:31 PM Re: Big Bank Doesn't Provide Early Disclosures Norman Paperman
Norman Paperman Offline
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Never. That never happens. smile I wouldn't think it would happen at a call center though.

You would think that the online application software at one of the big five would have a mechanism for spitting out a GFE.
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