Timing of AAN

Posted By: Many Hats

Timing of AAN - 03/12/09 06:49 PM

We received a mortgage application on 3/5/09.

Corect me if I am wrong, but, in orer to comply with reg B, we must notify the applicant of action taken within 30 days of receipt of application.

Okay, but in order to comply with RESPA, we are to provide initial disclosures within 3 days of receipt of a completed application.

So, if we were to send an ANN on 3/12, we would have complied with Reg B, but technically we violated Reg Z because we should have provided initial disclosures within 3 days.

Right?
Posted By: M Cockrell

Re: Timing of AAN - 03/12/09 07:00 PM

Originally Posted By: Many Hats
We received a mortgage application on 3/5/09.

Corect me if I am wrong, but, in orer to comply with reg B, we must notify the applicant of action taken within 30 days of receipt of [INSERT] a completed [INSERT] application.

Okay, but in order to comply with RESPA, we are to provide initial disclosures within 3 days of receipt of a completed [INSERT] an [INSERT] application [INSERT] (subject to applicant providing some specifics)[INSERT].

So, if we were to send an ANN on 3/12, we would have complied with Reg B, but technically we violated [INSERT] RESPA (HUD's Reg X) [INSERT] Reg Z because we should have provided initial disclosures within 3 days.

Right?
Posted By: ktac MITCH

Re: Timing of AAN - 03/12/09 07:12 PM

Originally Posted By: Many Hats
We received a mortgage application on 3/5/09.

Corect me if I am wrong, but, in orer to comply with reg B, we must notify the applicant of action taken within 30 days of receipt of application.

Okay, but in order to comply with RESPA, we are to provide initial disclosures within 3 days of receipt of a completed application.

So, if we were to send an ANN on 3/12, we would have complied with Reg B, but technically we violated Reg Z because we should have provided initial disclosures within 3 days.
Violations of both RESPA (not giving GFE, Servicing, booklet) & Reg Z (not giving early TIL) = assuming both RESPA and Reg Z applied