How are your institutions handling the collection of the 6 element needed for an application? We are looking at delaying collection of either income or property address till late in the process in order to allow for sufficient time to collect other data needed to generate a good Loan Estimate. Obviously, this is to avoid triggering the "application received" clock until a good LE can be generated.

Not sure I understand what you mean by delaying collection till late in the process.
Do you mean if someone comes in to fill out a 1003, you're going to not take their income or property address until they bring in other information to facilitate preparation of what you're calling a 'good Loan Estimate'?
Not only does this seem to be a nightmare to track half done applications, I just don't see how it could possibly fly past an examiner.
Maybe you could explain this concept a bit more to clarify?

What information are you thinking is needed and how long a delay is being considered?

What have you been disclosing until now?

I'm very interested in this question as well. The Loan Estimate requires several pieces of information that you may not be able to get from the 6 elements of a TRID application. Some of those items could be: Purpose, Product, Interest Rate (may not know the rate if client doesn't know what Product they want), Estimated Insurance & Assessments, HOA dues, Flood insurance, flood zone?, etc....

And what if the customer knows they want a loan, they have all 6 elements of an application, but they don't even know if they want a HELOC or a Home Equity Term Loan (one is TRID applicable, and one is not). There's got to be additional information you need from the client to even know if a Loan Estimate is required, regardless of the information that goes into the LE.

What have you been doing up until now?

That gets to the bottom of your question because, aside from the "wild card" 7th element in the RESPA definition of application, which many lenders have abandoned for one reason or another, nothing really changes on August 1 with regard to your question.

Right. The wild card 7th element allowed us to require additional information. Since that goes away, how can we require certain information needed for the LE?

You cannot, but what is so special that you need to have to complete and LE when an applicant comes to you and says, " I want to apply for a 30 year fixed rate mortgage on this house for sale over on Elm Street"?

My take is that you attempt to collect the information needed. Once the borrower gives the 6 pieces, you start the clock and disclose. If the borrower presents new info that affects your estimates you have a change in circumstance and redisclose. The CFPB feels (I'm not saying they are justified) that banks should be able to produce reliable estimates in 3 business days, so modifying your process so that you can get more than 3 days seems to fly in the face of the intent of the rule. The CFPB did spend a bit of time on this issue in their early webinars. If you proceed, I would carefully review the guidance they provided and ensure what you are doing is consistent with their advice.

In order to come up with a good appraisal cost (zero tolerance), we need to know the square footage of the dwelling which isn't one of the 6 items. So, we are considering leaving one of the 6 items off so that we can gather that information. How are others handling the appraisal cost element? Especially for construction?

Appraisal fee estimates are a big issue for us as well. See this thread concerning appraisal estimates:

http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=2016080#Post2016080

Leave it off of what?? The credit application???

You have the address. Heck, you can get the square footage off of Zillow or property tax rolls.

You guys need to start thinking outside of the box and quit just threatening to try to game the system as you are going to get yourself in a world of hurt.

Plus - what are you doing know??? Providing accurate estimates have not changed one iota with the LE versus GFE.

Thank you for the response. We've not offered mortgage products subject to GFE/HUD-1 in the past, and are now faced with having to disclose fees/costs on the Loan Estimate for initial construction loans (which were previously exempt). So, welcome feedback on how lenders have been getting appraisal costs for the GFE on initial construction - before you have plans, specs, etc., to assist?

I cannot speak for your market obviously, but our appraisers charge for the appraisal, not (generally for the property) being appraised. We have agreements with our rotation of residential appraisers that say we will pay $X for a standard single family appraisal, $XX for a 2-4 family, and so on.

Perhaps it is time to go through your appraiser list and work out some standard pricing, or determine median pricing for your pool of appraisers. We are not the only ones that have to start doing things differently, so will the vendors... and the slower they are to come around, sooner they will be outta business.

Thank you! That is helpful!