What constitutes an application for TRID is very different from the concept of application for the purpose of providing an adverse action notice under Regulation B or reporting data under Regulation C.It would take a large book to thoroughly explore all the nuances of applications under federal laws.However, once a creditor has received the six pieces of information, it has an application for purposes of the requirements of Regulation Z.
A submission may be in written or electronic format and includes a written record of an oral application. ![]() For example, if a creditors stated policy is to require all applications to be in writing on the creditors application form, but the creditor also makes credit decisions based on oral requests, the creditors procedures are to accept both oral and written applications. One difference, a prequalification is generally considered as an application under Regulation B, but not under Regulation C. The consumer submits answers to nine of the questions and informs the creditor that the consumer will contact the creditor the next day with answers to the other 11 questions. Although the consumer provided nine pieces of information, the consumer did not provide a social security number. If the application is denied, based on this limited information, an adverse action notice is needed. Reporting of data on the HMDA LAR is not needed at this time. The consumer submits only six pieces of information and informs the creditor that the consumer will contact the creditor the next day with answers to the other 14 questions. The six pieces of information provided by the consumer were the consumers name, income, social security number, property address, estimate of the value of the property, and the mortgage loan amount sought. Even though the creditor requires 14 additional pieces of information to process the consumers request for a mortgage loan, the creditor has received an application for the purposes of 1026.2(a)(3) and therefore must comply with the relevant requirements under 1026.19. ![]() At present the amount of application information needed to trigger integrated disclosures is worlds apart from the information needed for purposes of Regulations B and C. Maintain the struggle and keep reminding yourself that if this stuff was easy, then anyone could do your job.
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