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If we received a loan application that does not include a loan amount or an estimate of the value of the property to be a purchased, is that application considered complete? If so, do we have to issue a GFE? – IBA Compliance Connection

If we received a loan application that does not include a loan amount or an estimate of the value of the property to be a purchased, is that application considered complete? If so, do we have to issue a GFE?

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Without an estimate of the value of the property and the mortgage loan amount sought, the information you received from the customer is not sufficient to constitute an application. The RESPA regulations state that an “application” must include, in addition to the information you were provided, “an estimate of the value of the property, the mortgage loan amount sought, and any other information deemed necessary by the loan originator.” 12 CFR 1024.2(b). (Note that this definition of an application differs from the definition of a “completed application” for purposes of adverse action notices under ECOA and FCRA.) Because the customer has not submitted an “application” or “information sufficient to complete an application,” you would not be required to provide the applicant with a GFE. 12 CFR 1024.7(a)(1).