Is there a problem with a broker generating Loan Estimates when they are unsure who the creditor is going to be?

The rules don’t get that specific. The standard is best information reasonably available. The hook to issuing a Loan Estimate without a creditor’s name on it, meaning a broker is issuing a Loan Estimate and isn’t actually putting the name and address of the creditor on the form is that, despite using reasonable diligence to determine who the creditor will be, the broker is unable to determine who the creditor is going to be prior to issuing the Loan Estimate. In other words, the best information reasonably available does not include the name of the creditor; therefore, the creditor’s name can be blank.

Answered By: Andy Arculin