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#736751 - 05/21/07 02:00 PM Early Disclosures - No Address
Tortuga Offline
Member
Joined: Jan 2006
Posts: 90
Nebraska
Is it acceptable to provide early disclosures (TIL, GFE, Servicing Disclosure) before you have an address? Once a property is identified, do you need to re-disclose? Thank you.

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#736764 - 05/21/07 02:11 PM Re: Early Disclosures - No Address Tortuga
LoisLane Offline
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LoisLane
Joined: Oct 2001
Posts: 1,570
Wisteria Lane..
RESPA rules for the early TIL, GFE and Servicing Disclosure aren't applicable to applications in which a specific property hasn't been identified.
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#736771 - 05/21/07 02:17 PM Re: Early Disclosures - No Address LoisLane
Tortuga Offline
Member
Joined: Jan 2006
Posts: 90
Nebraska
Thank you for your response. Does it cause any problems if we do give them before we have an address? I assume we would need to re-disclose once we do have one, correct? Thanks again.

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#736810 - 05/21/07 02:38 PM Re: Early Disclosures - No Address Tortuga
LoisLane Offline
Diamond Poster
LoisLane
Joined: Oct 2001
Posts: 1,570
Wisteria Lane..
I don't think there is a problem if you give them before you have an address and yes in that case once you get an address you would need to re-disclose at that time.
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#736817 - 05/21/07 02:41 PM Re: Early Disclosures - No Address LoisLane
Tortuga Offline
Member
Joined: Jan 2006
Posts: 90
Nebraska
Thank you!

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#747526 - 06/06/07 02:13 PM Re: Early Disclosures - No Address Tortuga
Tortuga Offline
Member
Joined: Jan 2006
Posts: 90
Nebraska
I attended a webinar yesterday where they indicated that we do not need to rediclose once we have an address, as long as the terms have not changed. Would you agree? Thanks again.

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#747588 - 06/06/07 02:39 PM Re: Early Disclosures - No Address Tortuga
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
I would definitely agree...the address is not a particularly material-type disclosure. It's not going to make or break the bottom line. Even if the address changes, there is no need to redisclose, just correct it on the finals.

You can exempt disclosures if there is no address by regulation, however there is no rule against "over disclosure". It is often in keeping with the "spirit and intent" of the regulation and is often desirable to do so, so long as you have good facts and figures.
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