Hi,

I just got back from my 2 week vacation and it was wonderful. Now back to reality...

I have a lot loan secured by the borrower's brother's lot that he owns free and clear. The proceed will go to purchase a new lot that we plan to finance the construction on for the borrower. The loan app was dated 4/19/18 and we didn't send out LE. My processor thought it won't be applicable because we are not taking the lot that is to be purchased as collateral.

Are we out of TRID compliance? My instinct is yes, we are out of compliance and we don't care who owns the property or which property as long as it is consumer purpose and secured by any real property.

Yes - you are correct. TRID applies as long as it is consumer purpose and secured by any real property.

Thank you. Since we are out of compliance to send out LE within 3 days of application and ordered appraisal. How do you think I should handle this loan? We have an appraisal already. I am thinking to document the error and make sure to give her the training again on the loans that are subject to TRID. And send out LE asap with documenting the dates and send out CD.

Send the LE, wait the appropriate time follow with the CD and close and train and train and train. I agree.

Thank you Randy.

You have the appraisal. Has the borrower already paid for it? If yes, you owe a credit back to the consumer because you can't charge the consumer before the LE is received by the consumer. If you haven't billed the consumer for the appraisal, you can do so after the LE goes out.