When we receive an application from two married individuals or unmarried individuals who currently reside at the same address we mail a GFE, TIL and other disclosures naming both on each disclosure. The envelope is addressed to both applicants.

1024.20 states, "The list of homeownership counseling organizations distributed to each loan applicant under this section . . .". Should this be interpreted to mean that a list must be given to each applicant or mailed to each applicant in a separate envelope?

Sometimes you have to read further than the opening paragraph of a reg section to find how they want multiple applicants treated.

If there is more than one loan applicant, the required list of homeownership counseling organizations may be provided to any loan applicant with primary liability on the mortgage loan obligation.

Regulation X, Section 1024.20(a)(6):

(6) .... If there is more than one loan applicant, the required list of homeownership counseling organizations may be provided to any loan applicant with primary liability on the mortgage loan obligation.

If there is more than one application who will be primarily liable, you can provide one list to one of those applicants.

DUH! Thanks Joker and John. I thought I had read the reg the complete reg but now see that I didn't read the last sentence in 1024.20(6). Lesson learned. Thanks guys.

Oh,I have had my eyes glaze over reading some of this stuff and missed what was right in front of me, so I certainly understand, WHEDA.

They love to hide things! The beginning of that paragraph would make one want to skim over it.