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#1887382 - 01/16/14 02:51 PM Preapprovals and Homeownership Counseling List
Indy Banker Offline
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Joined: Aug 2010
Posts: 528
For a formal preapproval loan program, we're assuming the list does not have to be provided for a preapproval request only. We use the definition of an application under RESPA - which includes a property address - and since the borrower has not identified a property yet we do not have an "application" and thus the list would not have to be provided. We would provide the list when they identify a property and the preapproval requests transitions to a formal application. Does that logic sound reasonable?

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HOEPA and Homeowner Counseling Rule
#1887386 - 01/16/14 03:01 PM Re: Preapprovals and Homeownership Counseling List Indy Banker
dblack Offline
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Joined: Feb 2008
Posts: 263
AL
That makes sense to me since the list is a RESPA requirement.
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