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#2269457 - 04/21/22 03:03 PM Application Date precedes Loan Estimate
OldSchoolBanker Offline
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Joined: May 2005
Posts: 660
FL
I am reviewing a closed and funded correspondent loan and see where the original Loan Estimate precedes the application date by 1 day. I can see the Loan Originator printed the original application on 12/15, the same date as the Loan Estimate, however the Loan Originator date on the 1003 is 12/16.

Is this permissible? There is a series of change of circumstance during the processing which are handled correctly, but was curious about the early LE date. It appears to be more of a clerical issue than anything, but curious your thoughts.

Thank you in advance.
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TRID - TILA/RESPA Integrated Disclosures Rule
#2269459 - 04/21/22 03:15 PM Re: Application Date precedes Loan Estimate OldSchoolBanker
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,893
Galveston, TX
Applications are up to the lender or investor. Inconsistent dates however is usually a red flag for something else going on.
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#2269461 - 04/21/22 03:25 PM Re: Application Date precedes Loan Estimate OldSchoolBanker
OldSchoolBanker Offline
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Joined: May 2005
Posts: 660
FL
Thanks and I agree that can often be the case.
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#2269548 - 04/22/22 07:03 PM Re: Application Date precedes Loan Estimate OldSchoolBanker
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,542
On the Net
Well I suppose they could claim they had the 6 pieces of an app orally and reduced it to writing the day after. Technically the LE is due no later than 3 days after the TRID app. It's weak, but they could maintain they got the Reg B app following the TRID app and the Reg B info (1003) then included the GMI.

At the end of the day, it doesn't happen that way and I wouldn't want to argue that to an examiner. By bringing it up now the staffers will better understand the process and that following procedures is the best way to go. You don't have to remember what you said.
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