Before the loan advances, a training manager must resolve a TRID Loan Estimate timing issue in a disciplinary-risk review. What should happen?

Correct Answer

C) Collect only a bona fide credit-report fee before intent

Why this is correct: Under TRID (Regulation Z and X), a creditor's duty to provide a Loan Estimate is triggered by receipt of a loan application, defined as the consumer providing six specific pieces of information. However, a creditor is permitted to collect a bona fide and reasonable fee for obtaining the consumer's credit report before the consumer indicates intent to proceed with the application. This is the only permitted action before the application trigger is met and the intent to proceed is received. Therefore, "Collect only a bona fide credit-report fee before intent" is the compliant action to resolve the timing issue. Why the other choices are wrong: "Use an internal exception instead of the required federal disclosure or timing rule" is wrong because internal policies cannot override binding federal disclosure requirements. "Wait until a regulator asks for the file before applying the federal requirement" is wrong because compliance is mandatory at the time of the transaction, not retroactively upon inquiry. "Rely on oral agreement when the rule requires documented compliance" is wrong because TRID disclosures and consumer consent (like intent to proceed) generally require written records. Exam tip: Remember the "three buckets" before providing a Loan Estimate: you can collect the six application pieces, you can collect a bona fide credit report fee, and you can collect information to make a pre-approval or pre-qualification offer. Nothing else that constitutes a "fee" is allowed.