We received an application from a consumer borrower to build a residence. Loan officer assumed this was to build a primary residence and treated it as a TRID loan and we sent all of the appropriate early disclosures, Loan Estimate, etc. The consumer informed the loan officer that this was a construction loan to build a rental non-owner occupied rental property (which they have done in the past) and is a commercial loan purpose. The consumer is now completing a commercial loan application. Should the consumer loan application (TRID) be treated as a decline.....we do not have a consumer loan product to build investment properties; or would this be considered a withdrawal by the consumer? No credit decision/approval had been made on the consumer application. Thank you.

Just use the same application, discontinue consumer disclosures and move on. Not sure why you need to start over.

Thanks Randy