Ethics · 18% of the SAFE examhard
Correct answer: Once the MLO has received all six pieces of information that constitute an application under Regulation X, the borrower's instruction not to pull credit does not prevent the Loan Estimate obligation from arising
Under TRID (the TILA-RESPA Integrated Disclosure rule, Regulation Z 12 CFR 1026.2(a)(3)), an application is defined by the receipt of six specific pieces of information: (1) borrower's name, (2) borrower's income, (3) borrower's Social Security number (to pull credit), (4) property address, (5) estimated property value, and (6) the loan amount sought. Once all six elements are received, the lender has three business days to issue the Loan Estimate. Notably, the credit report is not itself a required element — the Social Security number (needed to pull credit) is. In this scenario, the borrower has provided all six elements. The borrower's preference not to have credit pulled does not eliminate the Loan Estimate obligation, though the lender cannot pull credit without permission. The LE is triggered by application receipt, not by a signed written form.
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