Effective date of changes 1/10/14.
Application dates prior to 1/10/14 with TBD and real deal dates after 1/10/14. Do the new rules effective 1/10/14 apply to application dates or property address dates when the loan becomes a real deal? IMO I think it's all based on application date, regardless of property address date. However, much disagreement. Has anyone else run into this and what are your thoughts?

I would say it's your application date at the time it starts your disclosure clock.

which is the day you received the property address. (just finishing Joker's sentence. )

But doesn't my disclosure clock for Reg Z start even before I get a property address? If I'm doing a pre-approval, Reg Z disclosures are provided... however not respa. The new rules that became effective 1/10/14 fall under Reg Z... so shouldn't it apply the same way? If I give Reg Z disclosures at my application date but my "real deal" date (property address date) falls after 1/10/14... the new rules shouldn't apply.

I'm not at all arguing... just trying to wrap my head around this.