For a purchase money loan, we ask the applicant for the purchase price in the application. if we have the “purchase price”, does that trigger TRID? Our software does not consider “purchase price” an estimated property value so is not indicating that the Loan Estimate is triggered. Our software has separate fields for “purchase price” and “estimated property value”. To me, it seems TRID is triggered. Thank you!

While I'm sure someone will come in a cite something within Regulation Z - my thoughts are with yours. If I'm paying X amount for a house - then that's what I believe it's worth.

If a purchase price is not an an estimate of the value of the property - nothing is - it would not even be considered an "estimate", it would be considered its fair market value.

Thank you for the confirmation! I did find the following in the commentary, which supports this as well:

1026.19(e)(2)(iii) - A creditor may ask for the sale price and address of the property, but the creditor may not require the consumer to provide a purchase and sale agreement to support the information the consumer provides orally before the creditor provides the disclosures required by 1026.19(e)(1)(i).

Curious - have you looked to see what was eventually put into your system as estimated property value - and if there was any difference?

No, but that would be interesting to check.

I agree