Texas resident here, applied with a local Texas lender for a Single Family mortgage. I have great credit and income, etc. After applying through the lender’s online portal, the lender refused to provide a Loan Estimate. Instead, he quoted a rate, PMI, and estimated monthly payment through email. When I asked for an official Loan Estimate document, he refused, saying their process is a little different and he only has his processing team issue LEs for customers that choose to move forward with him because the LEs are time-consuming to write up. A week has passed now. Doesn’t this violate the TRID 3-day rule? What should I do?
I am under contract on a property. I provided all information requested by the lender, including the six pieces of data that trigger a TRID (TILA-RESPA Integrated Disclosure) loan application: name, income, Social Security number, subject property address, estimated property value, and the mortgage loan amount sought, and more.
If you provided the six pieces of an application (property address, income, loan amount sought, estimated value, name, social), then yes, the 3-day waiting period started then. Let him know you’ll be including his message in your complaint to the CFPB.
Zander said: @Van
Yes—I provided each piece of the information required to trigger the 3-day period. Thank you!
After providing all the TRID items, a loan officer is required by law to provide you a Loan Estimate within 3 business days. You are owed this document and they may be in violation of the TRID Rule.
Ask for a closing cost worksheet. Some systems don’t produce an LE without a formal application. Most systems will leave out the address or value to avoid triggering disclosures for a non-client.
TX lender here, I honestly probably know exactly who you’re dealing with as I’ve run across this same issue before. They want you to lock in using them before they’ll even show you an actual LE. You should just tell them flat out the reason you don’t want to work with them is because they don’t follow CFPB requirements and you’ll be reporting them.
@Cove
Also, LEs aren’t ‘time-consuming to write up’ at all, that’s just not true. Any modern lender can get disclosures out within 24 hours at the absolute longest, most within an hour of the LO requesting it.
Fife said:
I won’t provide an LE without a purchase contract.
Same - company policy. AND I’m not going to waste time when I have no proof the buyer is under contract. Fortunately, I don’t have customers like this very often; I set expectations up front on the first call.
Zander said: @Dar
The only party “dictating” the LE is the CFPB.
Just because you see an address you want doesn’t mean you’re providing the sixth piece of information. If you’ve given the lender a contract, then he either needs to give you an LE or tell you he doesn’t want to work with you.
Are you under contract for the house? The vast majority of lenders will not issue a loan estimate if you are not under contract as they consider it not a real number for property value.
Crosby said:
Are you under contract for the house? The vast majority of lenders will not issue a loan estimate if you are not under contract as they consider it not a real number for property value.
Crosby said:
Are you under contract for the house? The vast majority of lenders will not issue a loan estimate if you are not under contract as they consider it not a real number for property value.
A contract to purchase isn’t required by TRID. Any lender not issuing an LE once only the 6 pieces of information are provided are violating TRID. Period.
If you don’t have an exact property or a property under contract you can run into this with retail lenders. A broker would be able to offer it right away.
Shan said:
If you don’t have an exact property or a property under contract you can run into this with retail lenders. A broker would be able to offer it right away.
I do have an exact property and I’m under contract on it.