My company has aligned the Reg B application and TRID application definitions. They have also taken the position ITP must be done electronically or in writing, and that a Notice of Incompleteness should not be issued for ITP since it is not something that is required in order to make a credit decision. Naturally, we end up with applicants who haven't provided ITP, but have provided documentation needed for underwriting review, and we approach the end of the 30 day Reg B period.
1. Are there lenders out there who have successfully separated the "application" definitions in TRID and Reg B, and start the timers at different points?
1a. If so, has anyone successfully said that they require ITP in order to even have an "Application" under Reg B?
2. Do others find it acceptable to issue an NOI for just ITP, and then issue another NOI after ITP is received to request verification documents?
I look forward to hearing how others do it!