Answer:
When HUD revised its Regulation X (RESPA) to create this whole new GFE mess, they worked only with their own regulation and ignored the many other definitions of application in closely-related applications such as Regulations Z, B, C and the like, so it is up to us to work out the conflicts and confusions. There has been no change (and probably won't be) to existing application forms, but what does need attention is your procedures. Look carefully through training materials and lending procedures to be sure that each regulation's definition of application and what it triggers is addressed. Also, establish documentation procedures for what information lenders have and when they had it. That has become more important than ever.
First published on BankersOnline.com 3/22/10
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