With regard to 1026.37 (a) (13) Rate Lock, does anyone take the language in to mean we should have a written rate lock agreement if we are representing the rate as locked on the Loan Estimate??

We are in the process of developing a written rate lock agreement due to the changes in the TRID rule. We decided to make the change based on the language in the preamble of the final rule published 12/31/13 on page 79919, right column.

"Regarding the situation where the creditor has a policy to honor the rate quoted without a rate lock agreement, both proposed 1026.37(a)(13) and 37(a)(13)-1 expressly contemplate a rate that is locked for a specific period of time pursuant to a rate lock agreement. Accordingly, where a creditor has a policy to honor the quoted rate, but does not lock the rate pursuant to a written agreement with the consumer, the creditor would disclose 'no' pursuant to 1026.37(a)(13)(i). The Bureau believes this disclosure is appropriate to aid the consumer's understanding of the transaction, because the creditor would not be bound by an agreement to provide the interest rate to the consumer at consummation."

Hope that helps.

That does help. I believe we need a Rate Lock Agreement as well. I knew I saw the language you provided somewhere, I just could not determine where! Thanks so much for your guidance.