I'm curious how you all feel about an institution collecting a rate lock fee on a preapproval application? Since we do not have a TRID application, I do not believe we not need to worry about the intent to proceed's prohibition on charging or incurring a fee before that document is returned.

Additionally, would you feel comfortable retaining the fee in the event that the preapproval application does not convert to a TRID application and result in an originated loan?

Any/all thoughts are appreciated. Thank you.

A rate lock fee on a preapproval? Property address or not that sounds like crossing a UDAAP line to me. Hopefully, this is a totally refundable lock fee.

I've never even heard of a rate lock fee. Application fee, yes but not a fee to just lock a rate. We sell all on secondary so that's not even possible here because the rate is tied to the property address as well as the borrower.

Years ago (late 1990's?) there were rate locks in a:

- rising rate environment, some lenders would charge a fee to lock the rate for a period of time rather than float.
- retreating rate environment to allow a change reducing the rate one time.