We’ve heard that some lenders are providing the CD earlier in the process when they don’t have the final numbers, effectively preparing it immediately upon receiving the title insurance binder. Is this meeting the intent of the rule? What are the repercussions of doing this?

We’re seeing some of that, not wide scale but we are seeing it. I think it really kind of violates the intent, because some lenders are just trying to get something out, to try to get the clock running to get to a closing date, but then I don’t know that they’re really putting forth the effort necessary to make the numbers right on it. I think that’s going to be a problem for them if they don’t get the results.

Answered By: Brent Laliberte