One of the six pieces of data included in the 1024.2(b) definition of an Application is "an estimate of the value of the property". The scenario posed to me is: Consumer meets with LO and states "I'm interested in buying the property at 123 Main St and it is listed at $220,000. I would like to get preapproved before I make an offer." The property is clearly identified but would the listing price qualify as an estimate of the value, thus triggering the need for a GFE?
"Best Practice" would, of course, be to issue a GFE, however, the LO didn't do that. Now, 6 days later, the consumer is back with an accepted offer at a purchase price of $209,000 and she wants to move forward with a full loan application. Is this going to be a "no cost" loan because the LO didn't issue a GFE on January 16th?