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Does a bank indicate "Yes" on the Loan Estimate for the rate lock question only once the agreement is in writing?

When it is appropriate to indicate “Yes” on the Loan Estimate for the rate lock question? Regulation Z (Truth in Lending Act) is unclear whether the bank only answers “yes” when the rate lock agreement is in writing.

The bank only marks “Yes” for the rate lock if there is a written rate lock agreement. See the preamble to the final rule 78 FR 80225: “Accordingly, where a creditor has a policy to honor the quoted rate, but does not lock the rate pursuant to a written agreement with the consumer, the creditor would disclose “no” pursuant to §1026.37(a)(13)(i). . .” (July 2018)

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