In the pre-TRID initial disclosures we were required to provide a consumer with the Servicing Disclosure at application. So if the customer were sitting in front of you with a new application you would provide them with this disclosure. And of course if the application was taken via the phone, internet, emailed or faxed we would include this disclosure with the other disclosure within three days of the application.

With the new TRID rules the servicing disclosure is included in the Loan Estimate which should be provided to the customer within three days of receiving a complete application.

Are we still required to provide this disclosure at application?

No.

37(m)(6) Servicing.

1. Creditor’s intent. Section 1026.37(m)(6) requires the creditor to disclose whether it intends to service the loan directly or transfer servicing to another servicer after consummation. A creditor complies with § 1026.37(m)(6) if the disclosure reflects the creditor’s intent at the time the Loan Estimate is issued.

By the way, the old requirement was to give the disclosure within three days of application.