Q: A broker-submitted application may contain all the information the lender requires, but the lender may not want to be bound by the mortgage broker‘s GFE. If the lender were to reject the application for this reason, would that rejection be subject to ECOA adverse action requirements and HMDA reporting?
A: HUD cannot interpret regulations promulgated by another federal agency. Please refer to the Federal Reserve Board for its regulations and staff commentary on the Equal Credit Opportunity Act (ECOA) ("Regulation B," 12 CFR part 202) and the Home Mortgage Disclosure Act (HMDA) ("Regulation C," 12 CFR part 203). The Federal Trade Commission (FTC) may also provide assistance with ECOA questions involving mortgage companies.
This can be found in GFE-General – FAQ #22 of HUD’s FAQs. HUD’s FAQs can be found at http://www.hud.gov/offices/hsg/rmra/res/respa_hm.cfm