I was asked by a borrower to order a FHA appraisal on her home before we did a "official" loan application. We collected $400.00 for her appraisal. When the appraisal was completed she decided to hold off on the loan. She has now came back to us to continue the refinance. My question is how do I handle the fact that the appraisal was done in June, paid for by her in June and the new disclosures will be dated today??

With all the new Reg changes I'm not sure what to do.....

there is probably a easily solution that I am not thinking of. Thanks!

I will respond only on the appraisal related issue. FHA appraisal is good for 6 months and goes with the property and not the lender. HVCC is not applicable to FHA so in this respect you have no concerns.

I think most state or federal regulators would say that if you pulled a credit report in June, you had enough info to constitute an application, and you should have provided disclosures. 

Beyond that, talk to your lender and see what they have to say.

I agree with Curt. Generally speaking, the day the credit report is pulled is the valid date of the intial application. Whenever I pull credit, I will email or mail disclosures and keep an unsigned copy in my file until it becomes a signed application. Initial discolures don't need to be signed to be in compliance. They just need to be sent out to the applicant.

Stacey, as long as you have the a copy of the initial credit pull and unsigned disclosures dated the same day, you should be good to go for MDIA compliance.