In the wholesale environment, if a loan is denied or it’s drawn from lender A and the broker submits the LE with Lender A on it to Lender B, is there any issue with Lender B accepting the LE that has Lender A’s information on it?

The rule doesn’t get into that level of specificity; there are things the rule’s silent on and doesn’t tell lenders how to operationalize it. This is one of them.

Technically, under the rule, the only time a revised Loan Estimate is required to be provided is if the lender wants to use a revised charge for purposes of the tolerances requirements.

Generally, even though there might not be a requirement to provide a revised Loan Estimate, in a situation where a lender did take a Loan Estimate from a broker that had a previous lender’s name on it, it would probably be a good idea to provide a revised Loan Estimate with the revised lender’s name on the Loan Estimate, just for consumer understanding purposes. I don’t think the rule would prohibit a lender from taking such a Loan Estimate, but just operationalizing that may be tricky. I understand some lenders are saying they wouldn’t take a loan that was previously submitted to another lender.

Once you get to the Closing Disclosure stage, you’re going to have to put the accurate lender’s name on that.

Answered By: Richard Horn