My concern with the TRID and the Reg B appraisal rule is that the appraisal disclosure has been added to the Loan Estimate. The Loan Estimate does not have to be provided if the application is denied or withdrawn within 3 business days(Commentary: 1026.19(e)(a)iii 3). However, there is no exemption in B for appraisal disclosure on denials within 3 days. It seems to me that lenders will have to come up with a way to deliver a separate appraisal notice to applicants who are denied within 3 days. Likewise with the pre-qualifications, the application is not a RESPA application because there is no property. But appears to meet the Reg B definition as it is a request for credit to be secured by a dwelling and therefore should be given the appraisal notice. Putting the disclosure on the LE seems to be a trick.

Any additional thoughts on whether creditors will still need to deliver a separate notice on denials/withdrawals within 3 days and pre-quals?

Correct, TRID will knock out Reg B but only when the LE is provided within 3 days of a Reg B app. So, denied and withdrawn w/ in 3 days and prequels or any other Reg B app that doesn't trigger TRID will still need the separate notice.

The Bureau may be trying to reduce the number of pieces of paper the consumer gets for a TRID loan to save trees (doubt it) or cut down on information overload (perhaps). But it doesn't do anything for the lenders who now have to have a different procedure for TRID and non-TRID applications for compliance with the Reg B notice requirement.