Good Morning,

What would be considered the initial application date in the following example when investors are involved?
The customer applies for a residential mortgage loan on 3/11/2019 and sent to the investor to make a decision on it. The investor denies the loan on 3/12/2019. The Bank reviews the loan for another investor or for a portfolio loan on 3/13/2019 and decided to do the loan. What is the initial loan application date?

In the scenario above, If the initial application date is 3/11/2019 and the investors sends out the LE within the 3 days, but decides not to do the loan and the Bank decides to do a portfolio loan on 3/13/2019 is a new LE required? Would that be considered a change in circumstances since the fees would change due to a new investor/Bank loan? Can the Bank rely on the original investors LE to meet the requirement in the Regulation for having the LE out in 3 days or would the clock reset if the Bank decides to do a loan for the customer? We are going to assume that the original investor did not denied the loan right away and the disclosures were required to be sent in this scenario.

Thank you,

3/11/19 - Investors are not the consumer's concern. Why would an investor be sending out a LE? Are you acting as a lender and selling the loan or are you just acting as a broker?

Read this and change the reference from GFE to LE.