Buyers collect Loan Estimates from two or three lenders, then sit on them while they decide. That’s normal, but the clock on those numbers doesn’t wait for you to finish comparing.
The intent to proceed deadline
Once a lender provides a Loan Estimate, federal rule lets it issue a revised one with different numbers if you don’t indicate your intent to proceed within 10 business days of that disclosure, or a longer window if the lender states one upfront. The CFPB is direct about what counts: you have to tell the lender you want to move forward. It can’t treat your silence as a yes.
Getting the estimate isn’t the same as getting approved
A Loan Estimate shows the terms a lender expects to offer if you move forward. It doesn’t mean the lender has approved or denied your application yet. That comes later, after you’ve indicated intent to proceed and the file moves into underwriting.
When the clock actually starts
The ten-business-day count starts on the day the lender delivers the Loan Estimate or drops it in the mail. It runs from that date whether you open the envelope right away or a week later.
The clock running before all of this
A different clock applies before any of this. The lender has to get you that first Loan Estimate within three business days of receiving your application, regardless of how the loan eventually turns out.
Comparing more than one lender’s numbers
If you’re collecting Loan Estimates from a few lenders before you decide, give yourself a system for tracking each one’s ten-business-day window so you don’t lose track while you compare. Send me the estimates you’re comparing and I’ll walk through what’s likely to hold and what’s more likely to move. I’m Diana Kim, REALTOR with eXp Realty, working with buyers across Greater Boston in English and Korean. This is general information, not legal advice.
Questions
Common questions
What happens if I don't tell my lender I want to move forward?
After 10 business days from the date the lender's Loan Estimate was mailed or handed to you, it can send a revised one with different numbers. The CFPB says the lender can't treat your silence as agreement to move forward, so you have to say so yourself.
Does getting a Loan Estimate mean I'm approved for the loan?
No. A Loan Estimate shows the terms a lender expects to offer if you move forward. The CFPB says the lender hasn't approved or denied your application at that point.
When does the ten-business-day clock actually start counting?
On the day the lender delivers the Loan Estimate or places it in the mail, the rule says, not the day you actually open it or call back.
Sources
- 12 CFR 1026.19(e)(3)(iv)(E) (Regulation Z, the TRID rule): a creditor may provide corrected disclosures when 'The consumer indicates an intent to proceed with the transaction more than 10 business days, or more than any additional number of days specified by the creditor before the offer expires, after the disclosures required under paragraph (e)(1)(i) of this section are provided.'
- Consumer Financial Protection Bureau, Ask CFPB, What is a Loan Estimate?: 'The lender must provide you a Loan Estimate within three business days of receiving your application.'
- CFPB, March 2015 TILA-RESPA Integrated Disclosure Rule Small Entity Compliance Guide, Section 8.8 (citing Comment 19(e)(3)(iv)(E)-1): 'Creditors should count the number of business days from the date the Loan Estimate was delivered or placed in the mail to the consumer, and use the definition of business day that applies for purposes of providing the Loan Estimate.'
- Consumer Financial Protection Bureau, Ask CFPB, 'My loan officer said that I need to express my Intent to Proceed...What does that mean?': 'The lender cannot assume that silence means you intend to proceed.'
Written by Diana Yeji Kim — REALTOR® at eXp Realty, serving Greater Boston in English, Korean, and Japanese.
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