Q: What if a creditor receives these six pieces of information, but needs to collect additional information to proceed with an extension of credit?
A: This definition of application does not prevent a creditor from collecting whatever additional information it deems necessary in connection with the request for the extension of credit, and creditors have a degree of flexibility that enables them to collect additional information for purposes of producing the Loan Estimate. (See section 6.8 for more information about collecting additional information prior to providing a Loan Estimate). However, once a creditor has received the six pieces of information discussed above, it has an application for purposes of the requirement for delivery of the Loan Estimate to the consumer, including the three-business-day timing requirement. (Comment 2(a)(3) -1)
The obligation to provide the Loan Estimate is not triggered until the consumer submits the six pieces of information that constitute an application under the TILA-RESPA Rule. Creditors may collect additional information, such as loan term or product, prior to producing the Loan Estimate, provided the consumer has not submitted all six pieces of information.