Store the application date, show the Loan Estimate due date on the file, record the borrower's intent to proceed with a signed or logged acknowledgement, and open the fee payment link only after that record exists. GoHighLevel can run the reminders, the acknowledgement, and the payment gate. The bottom line: the Loan Estimate clock and the fee rule are the two TRID details a broker's process most often gets wrong, and both are date and sequence problems that a workflow can enforce.
What the rule requires
According to the CFPB's guides, the Loan Estimate must be provided no later than three business days after the consumer submits a loan application, and no later than the seventh business day before consummation. An application means the six pieces of information that the rule lists, and the CFPB's FAQ says a request for a pre approval that includes all six starts the clock. A creditor may not impose fees on the consumer, other than a reasonable fee to obtain the credit report, until the consumer has received the Loan Estimate and indicated an intent to proceed. An Asurity summary notes that intent to proceed does not have to be in writing, must be documented, and cannot be given before the consumer has received the Loan Estimate. When a broker takes the application, the CFPB's small entity guide has a section on who delivers the Loan Estimate, so follow the arrangement with your lender.
The sequence to enforce
| Step | Date or event | What the system does |
|---|---|---|
| Application | Six items received | Starts the three business day clock and creates the due date |
| Loan Estimate due | Business day 3 | Reminder to the processor at day 1 and day 2; task escalates if not marked delivered |
| Loan Estimate delivered | Delivery date logged | Opportunity moves to Awaiting intent; the borrower gets a message with what to do next |
| Intent to proceed | Borrower signs or confirms | Tag Intent documented is added with the date and the method |
| Fees | Only after the tag exists | The payment link for the appraisal and other fees is released |
Business day arithmetic is easy to get wrong, so calculate the due date in your loan origination system and store it. HighLevel will remind from the stored date, and does not know your calendar of holidays.
Build it in HighLevel
- Add opportunity fields for Application date, Loan Estimate due, Loan Estimate delivered, and Intent to proceed date.
- When all six application items are in, the loan officer sets Application date and Loan Estimate due from the LOS.
- Use a Custom Date Reminder set to 1 day before Loan Estimate due to create a processor task, and another on the due date that escalates to the loan officer if Loan Estimate delivered is blank.
- When Loan Estimate delivered is filled in, send the borrower the next step by text, and send an Intent to proceed acknowledgement with Documents and Contracts for signature.
- When the document is signed, the Documents and Contracts trigger adds the tag Intent documented and fills the Intent to proceed date.
- Build the fee message so it only exists after that tag: use an If/Else on the tag, and send the Text2Pay payment link for the appraisal fee only when it is present.
- Use the Payment Received trigger to create a task for the processor to order the appraisal.
A message and an acknowledgement, written out
Text: Hi Dana, this is Priya at [Brokerage]. Your Loan Estimate was sent today. Please review it and sign the short acknowledgement here when you are ready to continue: [link]. We will not charge any fees until then. Reply STOP to stop messages. Acknowledgement: I have received the Loan Estimate dated [date] and I would like to continue with my application. Because the rule does not require writing, a verbal intent logged by the loan officer with the date and time also works, and the signed form is simply the easiest evidence to keep.
Worked example
A broker who takes 60 applications a month and sends 60 Loan Estimates will see about 3 a month slip past the due date if 5 percent of files are late (60 times 0.05). With a reminder at day 1 and an escalation at day 3, the processor sees each one before the deadline. The 5 percent is an assumption, and the rule is about each file, so even one late Loan Estimate matters.
Limits of this workflow
This describes timing and sequence, not legal advice on what counts as an application, a changed circumstance, or a valid intent to proceed. Have your compliance officer or counsel review the process, and keep the lender's requirements in view, because the lender is bound by the Loan Estimate.
Revised Loan Estimates after a lock or a change
The CFPB's small entity guide says a revised Loan Estimate is required no later than three business days after the date the interest rate is locked, and that a revised estimate can follow a changed circumstance within three business days of receiving the information. Add a field called Revised Loan Estimate due, set it from the lock date, and use the same reminder pattern. The rule counts business days from the event, so store the event date and let your LOS calculate the deadline.
What the processor needs on the card
The card should show four things at a glance: the application date, the Loan Estimate due date, whether intent to proceed is documented, and whether fees have been collected. A processor who sees a fee collected with no intent date can stop the file before a violation, which is the whole point of the gate.
How this was handled before
A processor tracked Loan Estimate due dates on a spreadsheet or in the LOS and sent the borrower an email. The payment link was often sent with the Loan Estimate, so intent to proceed was assumed. Gating the link makes the sequence visible.
What to measure
Track applications, Loan Estimates delivered within three business days, intent to proceed recorded before any fee, and fees collected before intent. The last number should be zero.
Questions people ask
When must a Loan Estimate be provided?
No later than three business days after the consumer submits a loan application, and at least seven business days before consummation, according to the CFPB.
Can a broker collect fees before the borrower says to proceed?
A creditor may not impose fees other than a reasonable credit report fee until the consumer has received the Loan Estimate and indicated an intent to proceed.
Does intent to proceed have to be in writing?
No, but it must be documented, and it cannot be given before the consumer receives the Loan Estimate.
To build the Loan Estimate tracker, start a GoHighLevel account here. Documents, payments, and date triggers appear in our capabilities demo.