Would a Guru be able to tell me if I understand the 'clarification' of issuing a LE vs CD when locking a rate?

The way I am understanding TRID 2.0 information simply is:

If it is an initial rate-lock, no. The LE must be delivered (my FI provides written Rate-Lock Agreements);
If it is an extended rate-lock, yes.

OR: May a FI use 1026.19(e)(4)-ii in using the CD for the initial rate-lock if the rate is locked the same day the FI plans to issue the CD?

Thank you.

I think I need to clarify...my FI is asking me if they can use CD's for initial rate locks for when the request for rate-locks are made a day before my FI plan to deliver the CD.

Thank you.

"...INITIAL rate locks for when the request for rate lock are made..."
Can you explain 'initial' and state who is making the request?

If the interest rate is locked on or after the date on which the creditor provides the Closing Disclosure and the Closing Disclosure is inaccurate as a result, then the creditor must provide the consumer a corrected Closing Disclosure, at or before consummation, reflecting any changed terms, pursuant to § 1026.19(f)(2). If the rate lock causes the Closing Disclosure to become inaccurate before consummation in a manner listed in § 1026.19(f)(2)(ii), the creditor must ensure that the consumer receives a corrected Closing Disclosure no later than three business days before consummation, as provided in that paragraph.

Perhaps I was thinking too much into this...thanks for bringing me back to this part, Randy. Appreciate it.

I think I understand. You want to know if you can do a CD for the Float to Lock, right? Meaning, can you issue a CD for the initial rate lock.

Originally, you could NOT do that. Back in the day the initial rate lock, which we called Float to Lock, had to be done with an LE.
I left the game for a while, and I heard from a buddy recently that you can do Float to Lock CDs now.