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#2041343 - 09/29/15 08:06 PM rate lock agreement in Iowa
Truffle Royale Offline

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Joined: Jul 2003
Posts: 17,400
I have just been told that Iowa Law says that you don't need a written rate lock agreement in order to mark a loan locked under TRID.
Questioning the source and would appreciate any Iowa lenders chiming in, especially with a citation if such exists.

Thank you.

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#2042556 - 10/05/15 06:24 PM Re: rate lock agreement in Iowa Truffle Royale
ahkcompliance Offline
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Joined: Sep 2008
Posts: 2,474
Midwest
We do not exercise rate lock agreements. We never have. We consider the rate locked at the time of application. We always honor that rate.

I don't have a citation though.

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#2042619 - 10/05/15 08:05 PM Re: rate lock agreement in Iowa Truffle Royale
ForceFull1 Online
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ForceFull1
Joined: Nov 2003
Posts: 251
smalltown Iowa
"Iowa Law says that you don't need a written rate lock agreement in order to mark a loan locked under TRID."
This was previously IBA's stance but they have since shifted gears and are recommending written rate lock agreements similar to the discussions here in BOL's TRID forum.
In our shop we are shifting from not obtaining written lock agreements to always getting them.

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#2042628 - 10/05/15 08:16 PM Re: rate lock agreement in Iowa Truffle Royale
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
Most of you that say we don't do written agreements but will honor the rates quoted were probably not around in the 80's when you could be upside down on the interest rate by 500 basis points in 45 days. Don't think for a minute that could not possibly happen again.

Plus, State law does not and would not override the CFPB rules.
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#2042700 - 10/05/15 11:41 PM Re: rate lock agreement in Iowa Truffle Royale
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
It could happen a lot sooner than 45 days. We used to call commercial customers a few times a day to say prime changed! (This was before banks had websites.)
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#2059365 - 01/19/16 08:59 PM Re: rate lock agreement in Iowa rlcarey
ComplyGuy Offline
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Joined: May 2015
Posts: 288
Originally Posted By rlcarey

Plus, State law does not and would not override the CFPB rules.

What CFPB rule are you referring too?

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#2059366 - 01/19/16 09:05 PM Re: rate lock agreement in Iowa Truffle Royale
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
The rule that says in order to report a rate as locked on the LE you have to have a written rate lock agreement with the consumer.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2059628 - 01/20/16 09:56 PM Re: rate lock agreement in Iowa ForceFull1
ComplyGuy Offline
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Joined: May 2015
Posts: 288
Originally Posted By ForceFull1
are recommending written rate lock agreements similar to the discussions here in BOL's TRID forum.
In our shop we are shifting from not obtaining written lock agreements to always getting them.

That is the most recent guidance I received from IBMC. IBMC also says that the written rate lock agreement does not need to be signed. Now that you are doing rate locks, are you getting them signed?

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#2060060 - 01/22/16 07:16 PM Re: rate lock agreement in Iowa Truffle Royale
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
We are getting them signed. We send them with the loan estimate. Our software has the signature line and not able to remove it.

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