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#2269380 - 04/20/22 01:35 PM pre-approval verification docs & TRID requirements
dutchbltz Offline
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Joined: Oct 2015
Posts: 189
Management wants to consider starting a true pre-approval program. (not a pre-qual program; which we already have)

A true pre-approval program would require the provision of verification documents; as it involves a comprehensive analysis of the applicant's credit worthiness.

How are institutions handling this in light of Reg Z's requirement that 'The creditor or other person shall not require a consumer to submit documents verifying information related to the consumer's application before providing the disclosures required by paragraph (e)(1)(i) of this section.'

We could do a pre-approval without a property address; which would keep us from having an LE trigger, but this doesn't say ''The creditor or other person shall not require a consumer to submit documents verifying information related to the consumer's application before providing the disclosures required by paragraph (e)(1)(i) of this section unless you don't have all of the data points that would typically require disclosure....' However I feel like nobody is probably issuing an LE for a pre-approval.... but maybe they are - or maybe they should be.... ?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2269446 - 04/21/22 01:33 PM Re: pre-approval verification docs & TRID requirements dutchbltz
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,839
Bloomington, IN
If you do not have all 6 data points then you do not have an application subject to TRID (1026.19(e)&(f), .37 & .38)
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The opinions expressed are mine and they are not to be taken as legal advice.

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