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#2252618 - 04/19/21 05:46 PM Preapproval
t0dd Offline
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Joined: Sep 2004
Posts: 229
We provided a customer with a Pre Approval letter which was requested online. The customer met the minimum credit score requirement for our portfolio, however the loan officer determined that another product offered through a mortgage broker (Quicken Loans) had a better chance in getting the loan approved and ultimately that was the case. My questions is what do we do if anything with our internal preapproval? Do we need to complete a denial notice even though we were able to find an alternative?

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Lending Compliance
#2252620 - 04/19/21 05:55 PM Re: Preapproval t0dd
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
You did not deny them, did you? There is nothing really to do.
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#2257815 - 08/06/21 07:19 PM Re: Preapproval t0dd
vdavis Offline
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Joined: Mar 2019
Posts: 13
we are finalizing our pre-approval procedures, there was a confusion whether the property address is required to issue a pre-approval. Is the property address required to estimate property taxes and insurance?? and do we need special disclosures to collect income documents (tax returns, paystubs, bank statements etc).

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#2257818 - 08/06/21 07:32 PM Re: Preapproval t0dd
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
If you have a property address, it is not a preapproval.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2257828 - 08/06/21 08:22 PM Re: Preapproval t0dd
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
what do we do if anything with our internal preapproval?

8. Action taken—preapproval request approved but not accepted. A financial institution reports that the preapproval request was approved but not accepted if the application was a request for a preapproval under a preapproval program as defined in § 1003.2(b)(2) and the institution made a credit decision approving the preapproval request but the application did not result in a covered loan originated by the financial institution.
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#2257873 - 08/09/21 04:30 PM Re: Preapproval t0dd
vdavis Offline
New Poster
Joined: Mar 2019
Posts: 13
Pre-approval procedures:

• If borrower does not provide a property address in pre-approval request, how will lending/origination issue LE? What can be issued in lieu of a LE for pre-approval purposes.
• Does Lending/Origination use Pre-Approval Application date or LE date for the "application date"
• If TRID applies, do we need signed Intend to Proceed before asking for any supporting documents required for comprehensive analysis (tax returns, pay stubs, W2s)?

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#2257877 - 08/09/21 04:53 PM Re: Preapproval t0dd
raitchjay Online
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Joined: Oct 2009
Posts: 9,110
OK
TRID disclosure requirements don't apply unless/until you have a subject property address.
Last edited by raitchjay; 08/09/21 05:02 PM.
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#2257892 - 08/09/21 06:56 PM Re: Preapproval t0dd
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
If you do not have an address and provide estimated closing costs that are not on an LE, make sure you remember the below. If you do provide an LE, you will be bound by that LE that you issue.:

H-26 Mortgage Loan Transaction—Pre-Loan Estimate Statement—Model Form
Description: This is a model of the statement required by §1026.19(e)(2)(ii) to be stated at the top of the front of the first page of a written estimate of terms or costs specific to a consumer that is provided to a consumer before the consumer receives the disclosures required under §1026.19(e)(1)(i).
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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