How are you collecting the fees you would normally have collected at time of application? Most of our fees were collected by the customer providing their credit card number or a bank account to charge. Now with the three day waiting period are you collecting CC #’s or Bank account # and then processing the fee after the waiting period? If so, do you assume they want the loan unless you hear otherwise and process the charges, order appraisal etc.
Has anyone moved to having the appraiser paid directly by the customer at the time it is done?

There is not a three day waiting period to collect the fees, you just cannot collect most fees until you have provided the early TIL, which you have up to three days to do, if you do not do it at the time of application.

You can collect a credit report fee at application, but can not collect any other fees until 3 days after the delivery date.

We are not collecting any fee until after we have provided the early TIL. Operationally, it's just much simpler to do it that way.

SF Do you do residential mortgages or HE loans? Are your lenders concerned about the additional delays in ordering appraisals etc if they are unable to contact the customers after the 3 day delivery timeframe to get the fees.
I agree w/ you on the cleanness of just waiting.
I also feel if I was out shopping for a loan I may have gone to several lenders and decided on lender #3 - now if everyone is collecting CC info up front - do I need to contact #1 and #2 and tell them not to process my fees?

How long are you taking to deliver TIL's after application?

Are you not able to, or have chosen not to give early disclosures at application?

We do residential 1-4 family mortgages, HE loans, lines of credit, multifamily mortgages, and commercial/mixed use mortgages. When we send the early TIL, we are sending a cover letter that tells them we will not process the application until we receive the application fee (and any other documents that were not provided initially). Yes, we realize that the process will be delayed, but, that's the way it is.

We're not collecting any fee at all until the borrower receives a copy of their TIL and agrees to proceed. I wouldn't collect their credit card number or checking account info at the time of application since, in my view, you can't charge their account just because they've received the TIL. You still need to hear back from the cusotmer stating that they want to proceed with the application. Otherwise, they could have applied at three banks and will be hit with three application fees the day after they get their disclosures in the mail.

Just Jay
Most of our RE Mortgage applications come in via phone or internet and ETIL is being mailed.

gotcha.

I'm glad you said this! I have a lot of LO's wanting to justify themselves by saying they didn't process it or it didn't clear until, blah blah.
I say do absolutely nothing until day 4...other than the credit report fee.

Is anyone pretty much in agreement with this?

Absolutely!

Good!
I actually have a LO on the phone now "complianing" about my stance on the matter. He's saying it didn't clear until the right day. I say I don't care. You imposed that fee upon the customer before due time.
Why must they continue to argue?