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Regulation B Applications vs TRID Application

Can a bank say they don't have a "completed" application (for Reg B purposes) until they have the 6 pieces of information required under TRID? And if yes, should it be documented in the procedures?

No. You cannot use the TRID definition of application to meet / satisfy other requirements under Regulation B. Regulation B does allow you some leeway in defining what is a “completed application”. If you want to line that up with TRID’s definition (6 items), that is fine; however, you could still have a Regulation B “application” (vs. “completed application”) before receiving the 6 items.
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Applicants and Applications

First published on 09/03/2017

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