Per TRID, we can not start the verification process until after we receive the customer's Intent to Proceed. We normally send a letter to the customer that pretty much says 'Thanks for the applying a loan with us. Here are the following items you will need to submit...' and we would list different items that would be needed like tax returns, pay stubs, etc along with the Early Disclosures. Can we still provide this letter with the Earlies or do we have to wait til we get their Intent to Proceed before we can send that request letter?

We can still pull the credit report before getting their Intent to Proceed, correct? I'm thinking yes because we can collect that credit report fee but no other fees until we get the Intent to Proceed.

Also, what is the true definition of verification process? Does it mean VOE, VOI, etc?

Thanks!

Timing of your letter asking for verification is flexible, as long as you don't delay issuing the Loan Estimate. That's all the regulation says about it. Put another way, you cannot require the verifying documents, etc., before issuing the LE.

A lot of banks include their punch list of required documentation as part of the cover letter that accompanies the LE (as you put it, "with the Earlies"), along with instructions on how to provide the intent to proceed and how much in fees will need to accompany the intent to proceed before you continue processing the application.

Yes, you can still pull credit and ask for a payment to cover the bona fide cost of the credit report before sending the LE and before getting intent to proceed. But that's the only cost you can impose before getting intent to proceed. You can require the credit report fee(s) to be paid with the application, if you wish.

Verification is what you make it. You need to support the information on the application so that you can underwrite the loan.

One more thought. Don't turn away any documents that the applicant provides with the application. The more the applicant provides up front, the better. Just don't slow up the LE to get more.

Thanks for your response!

Just to be clear, does 'verifying documents' include tax returns, paystubs, etc versus VOE, VOI, etc??

Thanks!

Bump.

peony - in my humble opinion, the answer to your question is yes.

Yes.