Good morning!

Our bank sells mortgage loans on the secondary market. Our investors will not purchase TRID loans where the timing rules have been violated (eg. Early disclosures sent more than 3 business-days after a TRID application is received). We regularly have LOs that miss the required TRID dates. Yes, it's a training issue, but that's another story for another time. We've been denying these applications as not meeting the investor standards. Is this the best that we can do with these applications?

Thanks!

You deny a loan because you didn't get your LE out on time? How can you possibly defend that?

Yeah - I would be very interested in the denial reason they put on that adverse action notice

Another anon here - if that was here, my next step would be to look at that set of denials - the ones specifically for timing issues - and break it out by the government monitoring information reported on your HMDA LAR (race, ethnicity, sex).

That denial reason is not defensible. How can you deny an applicant's request for credit because the lender's LO made an error?

If ANY of those applications are selected for regulatory review, the bank will be forced to do a look back with substantial fines and penalties. A bank timing mistake is not a reason for denial!
Concur with last anon to look at all the files denied for GMI, and get legal involved if any are minorities.

We've been denying these applications as not meeting the investor standards

Please explain how the applicant did not meet the investor's standards?

All,

Just read Randy's answer in this past weekend's Weekly Banker Briefing/Latest Compliance Topics, re: LE Not Provided by 3rd Business Day. If an investor won't purchase the loan due this error and the bank's policy doesn't allow it to book a loan with secondary market terms, how can it continue on with the file?

Thanks!

Well, you either do mortgage loans or you do not. The fact that you screw up loan disclosures and it makes the loan not salable in the secondary market is not a denial reason.

Here and at my previous employer - this would become a portfolio loan.

I find it amazing that in the five years TRID has been with us that this has not been sniffed out by your auditors, examiners, or even your investors researching your pull through!