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#2151588 - 10/28/17 04:23 PM Refinance loan estimate - but missing loan amount
Caroline Compliance Offline
100 Club
Joined: May 2015
Posts: 127
Is it possible to do a prequalification for a refinance and NOT be required to provide the initial Loan Estimate?

For example, borrower wants to refinance their 1st mortgage AND take out additional funds for home improvements. But they do not yet know exactly how much they will need. They are still getting estimates.

Thus, we do not know the loan amount.

Therefore, we don't have the required six pieces of information that trigger providing a Loan Estimate.


Thoughts? Anyone agree or disagree????



Thank you.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2151601 - 10/30/17 12:32 PM Re: Refinance loan estimate - but missing loan amount Caroline Compliance
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
For a refinance, regardless of any potential cash out, the loan amount will be at least the payoff of the existing loan.

Also, if they are still getting estimates then they have some ball park idea of how much money they need. The application piece in the regulation doesn't require the loan amount applied for to be exact.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2151610 - 10/30/17 01:31 PM Re: Refinance loan estimate - but missing loan amount Caroline Compliance
Caroline Compliance Offline
100 Club
Joined: May 2015
Posts: 127
I would think a compliance examiner would also make that same argument. A change to the loan amount can always be requested and documented, etc. Thanks Dan

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#2151656 - 10/30/17 05:49 PM Re: Refinance loan estimate - but missing loan amount Caroline Compliance
JC (Darth HMDA) Offline
Diamond Poster
JC (Darth HMDA)
Joined: Dec 2013
Posts: 1,399
CA
Agreed.. I wouldn't want to fight that battle (over estimated loan amount).
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

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