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This is Part 2 of the ongoing “Are we completing our GFEs correctly?” series.
“Are we completing our Good Faith Estimates (GFEs) correctly?” This is how I started out my blog back on November 17th and if you read it, you discovered that most credit unions are not completing the GFEs correctly. As you can imagine, there are more common mistakes being made on the GFE than just those I described in my previous blog.
Today’s common mistake: Dates
That’s right…Dates! I cannot tell you how many GFEs I have looked at where the dates contained in lines 1 through 4 on page 1 are either incorrect or incomplete. The most common mistake found in the Important Dates section is made to the date that must be entered on line 2. Often, credit unions enter the date the GFE was produced on this line. Other times, the date the credit union lists on line 2 has no logical explanation for its existence.
RESPA is very clear about what date needs to be entered on line 2. Appendix C to Part 3500 of RESPA states that within line 2, the loan originator must state the date until which the estimate of all other settlement charges for the GFE will be available and the date must be at least 10 business days from the date of the GFE.
If you are wondering what RESPA says about the other three date lines, here it is:
- In Line 1, the loan originator must state the date and, if necessary, time until which the interest rate for the GFE will be available.
- In Line 3, the loan originator must state how many calendar days within which the applicant must go to settlement once the interest rate is locked.
- In Line 4, the loan originator must state how many calendar days prior to settlement the interest rate would have to be locked, if applicable.
Stay tuned for more GFE common mistakes!
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