Late to the conversation.... I was told today that we have 1 investor offering a "Lock & Shop" program as described above (no address yet identified). I have multiple concerns about it. We do not have written lock agreements with borrowers. There is no fee for the 90 day lock, but if there is a need to extend the rate lock, there is an extension fee. There is also an option to purchase a "float down" for 1%. Currently we do not collect any fees until consummation of the loan.
If we were to go with this program, could we collect the float down and extension fee upfront because the application does not yet meet the 6 requirements for TRID (although the expectation is that it will become a loan subject to TRID)?
I am also concerned about fair lending. Currently we use a pricing desk, and depending on the borrowers information compared to investor requirements, the pricing desk sends back the best rates that are within our pricing parameters. Since we only have 1 investor offering this type of program, the borrower may not actually get the best deal.
Thoughts would be greatly appreciated.