We do not issue pre-qual certificates but we do allow people to allow for pre-qualification. (Note - this is different from an established pre-approval program which our Bank currently does not have).
IMHO, based on the information you collect, you have not triggered an application under TRID so I don't believe you would have any issues. Same for HMDA.
The applicant does not have a property identified, nor are you collecting income (based on what you have stated).
Good luck.
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.