CFPB TRID Sec. 13.5 - How does a consumer indicate an intent to proceed with a transaction?

Compliance > Regulation Z - TILA / TRID Specific > General Info
Q:  How does a consumer indicate an intent to proceed with a transaction?
 
A:  A consumer indicates intent to proceed with the transaction when the consumer communicates, in any manner, that the consumer chooses to proceed after the Loan Estimate has been delivered, unless a particular manner of communication is required by the creditor. (§ 1026.19(e)(2)(i)(A))
 
This may include:
  • Oral communication in person immediately upon delivery of the Loan Estimate; or
  • Oral communication over the phone, written communication, communication via email, or signing a pre-printed form after receipt of the Loan Estimate.
 
A consumer’s silence is not indicative of intent to proceed. (Comment 19(e)(2)(i)(A)-2)
 
The creditor must document this communication to satisfy the record retention requirements of § 1026.2
 
 
This information can be found in the CFPB's TILA-RESPA Integrated Disclosure rule compliance guide - http://www.consumerfinance.gov/regulatory-implementation/tila-respa/
 

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