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#2235323 - 04/21/20 04:46 PM Technical glitch in system (violation?)
awilli Offline
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Joined: Oct 2014
Posts: 291
If we have an online form that is completed to submit an application, and the customer submitted it, however, due to something that was input into the application, it caused a technical glitch in the system, and therefore it did not come into our queue at the bank. We discovered the application a few days later, and then proceeded to complete the loan estimate and send out all disclosures. Disclosures were sent within 3 days after we saw the application, but it was after 3 days that the customer "thought" it was submitted. Any thoughts on whether this would be a timing violation?
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TRID - TILA/RESPA Integrated Disclosures Rule
#2235337 - 04/21/20 06:26 PM Re: Technical glitch in system (violation?) awilli
Truffle Royale Offline

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The issue is not the customer's thought process, but rather when the application was received by your bank.
did the glitch prevent the loan from being received or just from being placed in the queue?
If it's the former, I think your dates are ok.
If it's the latter, I would consider it a bank error and say you have a timing violation. But it's a one off so I doubt it would cause a real issue in an exam.

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#2235339 - 04/21/20 06:58 PM Re: Technical glitch in system (violation?) awilli
awilli Offline
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Joined: Oct 2014
Posts: 291
This helps. Thank you
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Say what you mean, mean what you say, but don't say it mean.

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