CFPB TRID Sec. 13.7 - Can creditors provide estimates of costs and terms to consumers before the Loan Estimate is provided?

Compliance > Regulation Z - TILA / TRID Specific > General Info
Q:  Can creditors provide estimates of costs and terms to consumers before the Loan Estimate is provided?
 
A:  The TILA-RESPA Rule does not prohibit a creditor or other person from providing a consumer with estimated terms or costs prior to the consumer receiving the Loan Estimate.
 
However, if a person (such as a creditor or broker) provides a consumer with a written estimate of terms or costs specific to that consumer before the consumer receives the Loan Estimate, it must clearly and conspicuously state at the top of the front of the first page of the written estimate “Your actual rate, payment, and costs could be higher. Get an official Loan Estimate before choosing a loan.” (§ 1026.19(e)(2)(ii); Comment 19(e)(2)(ii)-1)
 
There are other restrictions on the form of this statement to assure it is not confused with the Loan Estimate:
  • Must be in font size no smaller than 12-point font.
  • May not have headings, content, and format substantially similar to the Loan Estimate or the Closing Disclosure. (§ 1026.19(e)(2)(ii); Comment 19(e)(2)(ii)-1)
The Bureau has provided a model of the required statement in form H-26 of appendix H to Regulation Z.
 
 
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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