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#2087539 - 07/12/16 02:52 PM application question
mdog76 Offline
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Joined: Jan 2007
Posts: 645
Is there a part of the regulation that says income doesn't need to be verified in order to provide an LE and can rely on what the customer states as income on the app? A loan officer has a loan request that was withdrawn by the customer but I think we missed issuing a LE.

Thank you.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2087543 - 07/12/16 03:00 PM Re: application question mdog76
John Burnett Offline
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John Burnett
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Posts: 40,086
Cape Cod
Not precisely, but you can't condition your provision of the LE upon the consumer's providing documentation of income or other information on the application. You have to provide it within 3 business days of receipt of the application (with the 6 elements), unless you decline the application (or the consumer withdraws it) before the end of the three-business-day period.
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#2087546 - 07/12/16 03:04 PM Re: application question mdog76
mdog76 Offline
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Joined: Jan 2007
Posts: 645
I can use that because the LE is just a "good faith" disclosure of costs related to the transaction and based upon the actual income of the applicant at that point in time. Just trying to get my explanation down to take to the loan officer.

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#2087655 - 07/13/16 12:28 PM Re: application question mdog76
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Yes, the LE is a disclosure based on the best information available at the time it's issued. If the applicant's income doesn't support the loan request at all, there won't be a closing -- you'll deny the loan request. If the documented income doesn't meet your criteria for the loan program requested but will support a loan from a different program, you can counteroffer and, when the applicant says, "Yes, let's do that," you'll have an intent to proceed and you will have a changed circumstance to justify issuing a revised Loan Estimate with adjustments to the costs related to the change in program.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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