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 “work sheets” and “loan scenario” forms that come with no legal requirements for accuracy, and were not even contemplated under the reforms.

The work sheets purport to contain much of the information provided by a GFE. Typically they are issued only when shoppers do not provide — or are asked not to provide — key information that constitutes an “application” under HUD’s definition in the rules.