If we have issued a counteroffer for a real estate loan request, are we required to provide the GFE/servicing disclosure/estimated TIL? Could this be treated the same as a denial and we are not required to provide if we notify them within 3 business days.

Your time should start ticking if they accept the counteroffer...otherwise it will stand as a denial.

I just found out the "counteroffer" has to do with cleaning up some outstanding past due balances on their credit report. Thanks for the help!
I may be weird but I could sit & read these posts all day!! Reading them makes me realize just how much I do not know....yet.

Oh, am I glad to hear someone else is reading tons and feeling overwhelmed too!

That said, to carry this subject out a bit further...
My institution operates in the unique position of receiving applications from front line banks who forward it to our bank for underwriting and processing.

Feds say for HMDA purposes, application date is date we receive application in house.
Discussion is now going on regarding disclosures. If we don't get the processing instructions (costs) with the application, we can't send out the TIL/GFE. So should we hold up application date till instructions get here OR is there a way to document two seperate dates to satisfy the two different regs?

In theory, I would say that the application should be date-stamped when you receive it. This should start your 3 days. As far as I am concerned, not having the cost list would not constitute an "incomplete application" as it has nothing to do with the borrower's info...my suggestion would be to not accept an application without the cost-list included at the same time. If it were my responsibility, I believe I would require the originators to fax all information the day they take the application...otherwise you could have a nightmare on your hands!

Thank you, Joker! That is my contention also.

Thank you to all of you who post and reply. When you're the only compliance person in the building, it's imperative to have someplace to go to talk it out!