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#2201839 - 01/02/19 02:21 PM Preapproval / Prequalification - disclosures
Shih_Tzu_Lvr Offline
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Joined: Nov 2011
Posts: 86
what disclosures are required for a preapproval / prequalification? I know an LE is not required until a property is found.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2201844 - 01/02/19 02:51 PM Re: Preapproval / Prequalification - disclosures Shih_Tzu_Lvr
rlcarey Online
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rlcarey
Joined: Jul 2001
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Galveston, TX
It is an application for a mortgage loan. Outside of the six pieces of information that triggers TRID disclosures, none of the other regulatory requirements have such a limitation.
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#2201862 - 01/02/19 03:33 PM Re: Preapproval / Prequalification - disclosures Shih_Tzu_Lvr
Shih_Tzu_Lvr Offline
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Joined: Nov 2011
Posts: 86
So your saying things like

MA 184
Privacy
ARM Disclosure
Charm Booklet
Evidence Of Joint Application
ECOA
US Patriot Act
Housing Counselor Notice
Appraisal Notice

All apply?

I assume the Home Loan Tool Kit applies when a property is found.

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#2269288 - 04/18/22 06:23 PM Re: Preapproval / Prequalification - disclosures Shih_Tzu_Lvr
Tesla Offline
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Did you ultimately require all those disclosures Shih Tzu Lvr? We are standing up a preapproval program now and I am getting push back from the lenders on requiring these disclosures as they say at their other shops it was not required. I can see appraisal disclosure, joint intent, Patriot Act, and ARM disclosures if that is the type of loan they are looking for - but privacy- I am not sure - as they are not our "customer" at preapproval stage, right?

Also, on the appraisal notice, I read on another thread it was only required if they used the preapproval app for the new loan too. Why would there be a difference? If you make them complete a new application for the end loan, does that mean you don't give the appraisal disclosure on just a preapproval app?
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#2269294 - 04/18/22 07:50 PM Re: Preapproval / Prequalification - disclosures Shih_Tzu_Lvr
rlcarey Online
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rlcarey
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Galveston, TX
Regarding the appraisal disclosure - they are saying that a preapproval application is NOT: in connection with an application for credit that is to be secured by a first lien on a dwelling?

Privacy:

(2) Examples in the case of a financial institution other than a credit union. For purposes of this paragraph (e)(2), “you” is limited to financial institutions other than credit unions.

(i) An individual who applies to you for credit for personal, family, or household purposes is a consumer of a financial service, regardless of whether the credit is extended.
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#2269355 - 04/19/22 06:23 PM Re: Preapproval / Prequalification - disclosures Shih_Tzu_Lvr
Truffle Royale Offline

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I wonder if the LOs are mixing up prequalification with a preapproval when they say other shops didn't require disclosures?

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