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Application Date & RESPA Disclosures

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Question: 
What constitutes the application date in regards to RESPA disclosures? The day the applicant applies or the credit report date? If I do not pull credit for 3,4 or 5 days do I need to re-disclose?
Answer: 

Application is a defined term in HUD Reg X Section 3500.2(b). It doesn't have anything to do with the credit report date. I'd recommend you start by reading that definition.

I'm not sure what you are asking about re-disclosing. If your credit terms are changing based on what you found out in the credit report and this impacts the figures in the GFE, you are not required to re-disclose on a new GFE, but certainly could as a matter of good customer service and to ensure there are no surprises at the closing table.

First published on BankersOnline.com 9/17/07

First published on 09/17/2007

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