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Requiring a completed URLA to provide GFE?

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  • #2581
    crowlv
    Member

    Is the bank allowed to required a completed Uniform Residential Loan Application as the 7th piece of information (in addition to the other 6 pieces of information;the borrower’s name, monthly income, social security number, property address, an estimate of the value of the property, and loan amount )?

    I’m asking because we have been using the general rule of requiring the 6 standard pieces of information and a completed URLA but a consultant just told me that is a violation because I can’t require them to complete the liabilities, etc sections of the application in order to provide the GFE (her reasoning was that requiring this additional information would inhibit shopping) …

    I’m struggling with this a little because in RESPA is defines application as the “submission of a borrower’s financial information in anticipation of a credit decision relating to a federally related mortgage loan, which shall include the borrower’s name, the borrower’s monthly income, the borrower’s social security number to obtain a credit report, the property address, an estimate of the value of the property, the mortgage loan amount sought, and any other information deemed necessary by the loan originator”.

    I know we can’t require verification documents but do you think it’s a problem to require a completed mortgage application? I cannot seem to find anything that provides guidance on what we cannot require as “any other information deemed necessary by the loan originator” except no verification docs.

    I know that the 7th piece of information goes away very soon but in the meantime, are we allowed to required the completed application?

    Thanks for your input.

    #3095
    dmurray
    Participant

    IMO, I think if you have the first 6 pieces of info and you’re just waiting for the applicants to complete an URLA, you’re asking for trouble. You had enough information to get the Earlies started. Now requiring them to complete the application prior to closing, different story…

    This is really my opinion and not necessary the views of others.

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