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#2282542 - 03/23/23 03:54 PM Homeownership Counseling Notice
Anonymous
Unregistered

Loan app dated 8/26/22- Housing Counseling Agencies Notice dated 8/29/22 but signed and dated by customer on 9/2/22.

Would this be a violation since the signature date is more than 3 days after application date?

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#2282554 - 03/23/23 04:11 PM Re: Homeownership Counseling Notice Anonymous
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,220
Galveston, TX
There are no signature requirements there are only delivery requirements.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2282557 - 03/23/23 04:22 PM Re: Homeownership Counseling Notice Anonymous
Anonymous
Unregistered

but they did sign it and date it .. so to me it looks like it was not delivered within the 3 day period .... and is not following the regs requirements?

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#2282559 - 03/23/23 04:27 PM Re: Homeownership Counseling Notice Anonymous
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,220
Galveston, TX
Then you have fallen on your on sword by requiring a signature, if you feel that way. Delivery includes dropping it into the mail by the third business day - is that not what happened? Do you not document that in some manner, i.e. dated cover letter with policies and procedures that dictate that disclosuresare mailed the same day as they are dated..
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2282561 - 03/23/23 04:38 PM Re: Homeownership Counseling Notice Anonymous
Anonymous
Unregistered

No the loan officer does the early disclosures probably 95 % of the time the same day as application and typically the customer stops back in the bank the next day and picks them up. Small town. Except in this case that signature shows too many day have passed and she signed and dated the loan estimate too with the same date ...

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#2282562 - 03/23/23 04:48 PM Re: Homeownership Counseling Notice Anonymous
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,220
Galveston, TX
Well, if you think that is what happened then I do not know what your question is. If you failed to deliver in person or mail the disclosures within three business days, then you have a violation.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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