On July 31, 2019, the Consumer Financial Protection Bureau (CFPB) released five new TILA-RESPA Integrated Disclosures (TRID Rule) Frequently Asked Questions (FAQs) related to loan estimates. The five new FAQs provide answers to the following questions:

  • When is a creditor required to provide a loan estimate to a consumer?
  • Can creditors require consumers to provide additional information (other than the six pieces of information that constitute an application under the TRID Rule) in order to receive a loan estimate?
  • Can creditors require consumers to submit verifying documents in order for the consumer to receive a loan estimate?
  • Is the requirement to provide a loan estimate triggered if the consumer submits the six pieces of information in order to receive a pre-approval or pre-qualification letter?
  • What if a creditor needs to collect additional information (other than the six pieces of information that constitute an application for purposes of the TRID Rule) or verifying documents to process a pre-approval or pre-qualification request?

Note that the CFPB explains that not providing the loan estimate when required can, in certain circumstances, be deemed an unfair, deceptive or abusive act or practice.

Author

John Zasada, JD, CAMS – Regulatory Consulting Director, Financial Institutions Group. John can be reached at zasada@doeren.com.