Lenders exploit a loophole
So how have the first two weeks of the reforms been going? Not exactly as planned. Many loan officers and lending institutions are sidestepping the new, price-bound GFE by giving shoppers "worksheets" and "loan scenario" forms that come with no legal requirements for accuracy, and were not even contemplated under the reforms. In effect they are substitutes for the new GFEs but, in the wrong hands, are wide open to lowballing and bait-and-switch games. The worksheets purport to contain much of the information provided by a GFE. Typically they are only issued when shoppers do not provide — or are asked not to provide — key information that constitutes an "application" under HUD's definition in the rules. For example, if a consumer does not provide the address of the property to be financed, there is no "application" and therefore no requirement to issue a tolerance-bound GFE.