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#1761582 - 11/28/12 04:00 PM
Big Bank Doesn't Provide Early Disclosures
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Diamond Poster
Joined: Aug 2012
Posts: 1,700
48.934476, -114.343735
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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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Maybe you just wanna fly the plane yourself. Well good luck pressing take off, then auto pilot, then land.
CRCM
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#1761597 - 11/28/12 04:09 PM
Re: Big Bank Doesn't Provide Early Disclosures
Norman Paperman
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Diamond Poster
Joined: Sep 2011
Posts: 1,648
A CU, Where Regs Don't Apply
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From: http://www.bankersonline.com/articles/v07n02/v07n02a2.htmlRegulation 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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#1761681 - 11/28/12 05:18 PM
Re: Big Bank Doesn't Provide Early Disclosures
Matt_B
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Diamond Poster
Joined: Aug 2012
Posts: 1,700
48.934476, -114.343735
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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".
_________________________
Maybe you just wanna fly the plane yourself. Well good luck pressing take off, then auto pilot, then land.
CRCM
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#1761687 - 11/28/12 05:21 PM
Re: Big Bank Doesn't Provide Early Disclosures
Norman Paperman
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10K Club
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
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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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The opinions expressed are mine and they are not to be taken as legal advice.
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#1761697 - 11/28/12 05:33 PM
Re: Big Bank Doesn't Provide Early Disclosures
Norman Paperman
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Power Poster
Joined: Aug 2001
Posts: 7,351
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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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The more you sweat in training, the less you bleed in battle.......
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#1761771 - 11/28/12 06:39 PM
Re: Big Bank Doesn't Provide Early Disclosures
Norman Paperman
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10K Club
Joined: Jul 2001
Posts: 83,229
Galveston, TX
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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 That never happens in smaller banks.......
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1762299 - 11/29/12 05:31 PM
Re: Big Bank Doesn't Provide Early Disclosures
Norman Paperman
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Diamond Poster
Joined: Aug 2012
Posts: 1,700
48.934476, -114.343735
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Never. That never happens. 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.
_________________________
Maybe you just wanna fly the plane yourself. Well good luck pressing take off, then auto pilot, then land.
CRCM
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