Loan Estimate (LE) and Good Faith Estimate (GFE)
The Loan Estimate (LE) is a three-page disclosure that helps consumers compare a mortgage's proposed terms, payments, and closing costs. For most covered closed-end consumer mortgages, the TILA-RESPA Integrated Disclosure (TRID) rule replaced the Good Faith Estimate and initial Truth-in-Lending disclosure with the LE for applications received on or after October 3, 2015. The Closing Disclosure (CD) is its closing-stage counterpart. The 2018 TRID amendments did not introduce the original forms. CFPB: the new disclosure forms
Loan Estimate and Good Faith Estimate
The GFE remains relevant to reverse mortgages. It is not the form used to compare a current TRID loan with its Closing Disclosure; compare the LE with the CD. HELOCs and other excluded transactions have different disclosure requirements. CFPB: what is a Loan Estimate?
What starts the disclosure clock?
For TRID, an application consists of six items: the consumer's name, income, Social Security number to obtain a credit report, property address, estimated property value, and requested mortgage amount. The lender cannot delay the LE by demanding additional verification documents first. CFPB TRID application FAQs
The creditor generally must deliver or mail the LE within three business days after receiving the application and at least seven business days before consummation. For the three-day application deadline, business days are days when the creditor is open for substantially all business functions. The seven-day waiting period uses all calendar days except Sundays and federal legal holidays. 12 CFR 1026.19(e)(1)
Except for a bona fide and reasonable credit-report fee, fees cannot be imposed until the consumer has received the LE and indicated intent to proceed. Receipt alone does not satisfy both conditions. 12 CFR 1026.19(e)(2)(i)
What the form shows
- Loan terms: Loan amount, interest rate, scheduled principal and interest, and whether those figures can increase. Separate feature rows identify prepayment penalties and balloon payments.
- Projected payments: Principal and interest, mortgage insurance if applicable, estimated escrow, and estimated total monthly payments.
- Costs at closing: Estimated closing costs and cash to close.
- Comparisons: The five-year payment/cost and principal figures, Annual Percentage Rate (APR), and Total Interest Percentage (TIP).
TIP describes total interest over the loan term as a percentage of the loan amount. It does not stand for TILA. An adjustable rate is identified through the product description and applicable rate/payment disclosures; it is not a replacement label for a prepayment penalty or balloon-payment feature. 12 CFR 1026.37; CFPB Loan Estimate explainer
Estimates, rate locks, and revisions
Receiving an LE does not constitute loan approval or automatically lock the rate. The rate-lock section states whether the interest rate is locked and, if so, until when. Good-faith and tolerance requirements still govern disclosed costs; an LE is not simply binding for one day. CFPB Loan Estimate explainer
To reset applicable tolerances, a revised estimate must have a permitted reason, such as a qualifying changed circumstance. Revised LEs have timing restrictions: the consumer must receive one no later than four business days before consummation, and the creditor cannot issue it on or after the date it provides the CD. 12 CFR 1026.19(e)(3)–(4)
Closing and record retention
For covered transactions, the consumer generally must receive the Closing Disclosure at least three business days before consummation. This is not a HUD-1 delivery rule. 12 CFR 1026.19(f)(1)(ii)
The creditor generally retains evidence of compliance with the LE requirements for three years after the later of consummation, required disclosure, or required action. The completed CD and related documents have a separate five-year retention rule after consummation. These are not one universal “three years after signing” rule for the entire loan file. 12 CFR 1026.25(c)(1)
Related concepts: the mortgage application, disclosure tolerances, and the Projected Payments table.
Source material
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