Some of our originators are using LP for prequalifying potential mortgage customers. They have been giving the typical "early" disclosures (GFE for example) at this point instead of later after the application is completed. I'm seeing disclosures dated prior to the application. Is this a problem as long as they are accurate?

What is LP?

I assume LP means a "Loan Processor." I don't see a RESPA or TIL problem with giving the disclosures early, however, if the disclosures a substantially off you would want to redisclose (for customer service reasons). Technically, RESPA doesn't apply to prequalifications, until a home is identified. Why are they giving the disclosures at all?

David, I understand where you are coming from and I am like you as to why they are giving the disclosures at at a pre-qual stage. My concern is that with a pre-qual, the disclosures provided could pre-date the application by some considerate period of time. Don't you run the risk with the examiners of not providing new/duplicate disclosures within three business days following the receipt of a written applicationas as stated in RESPA and Reg Z?