HUD issued that release on how they would approach the new rules. HUD cannot force the other agencies to follow suit. No other agency (to my knowledge) issued a similar reprieve, althoguh I do recall where the FDIC suggested that they understood that there is a learning curve to these things, and would handle each bank accordingly.
IMO, unless there was an overall system failure, no bank should have been using the olf GFE for any new application received after January 1st. HUD had fillable forms available on their site with direction for several months leading up to the start of the year, and any bank could have manually completed forms if they had to come January 1st. No rule dictates that the form has to be system generated, or that it could nto be completed by hand.
If you knowingly were using the old GFE, even on a limited basis, for new applications after the 1st, then IMO you were not acting in good faith.
At this point, I would plead ignorance, bow my head, and ask how you can resolve this issue to move forward.
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