Disclosed Too Early?

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Question:

For initial disclosure purposes on a retail loan, we usually take phone apps. We obtain the borrower's signed credit authorization and then once credit is pulled we call the borrower and finish filling out the application. I have always been told that we need to send out our initial disclosures within three days of either the credit report or the signed application, whichever came first. I am now being told I am out of compliance because I disclosed too early. Please let me know what is the rule?

Answer:

You've confused me with some of your terminology. Let me clarify by first saying that early TIL disclosures and RESPA disclosures are only required on residential mortgage transactions subject to RESPA, not to all retail credit transactions. If you are giving initial TILs for all retail loans, you are doing way too much work.