I know the technical definition of "application" in RESPA (the 6 items that make up an application) - and Truth in Lending refers to RESPA for the definition with respect to providing an ETIL.

Our problem is with pre-approvals when we don't have a property address (one of the 6 appliation items). We're thinking we should send the GFE prior to the property being identified in order to obtain verifications & issue a commitment letter to the applicant. Should we also be providing the ETIL when we send the GFE?

In the past, RESPA said we had to have an address for it to be an "application", so we didn't send either of these 2 documents until the property was identified. The new verification restrictions are what is causing us to change our approach.

Thoughts?

Refer to this thread:

http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1323149&gonew=1#UNREAD