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#1241900 - 08/29/09 12:38 AM
Re: When is it an online "application"?
Zuki
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10K Club
Joined: Oct 2000
Posts: 10,204
Toano, VA
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In the applicant's mind, it's an application the second s/he clicks the button labeled "Apply Now".
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#1241911 - 08/29/09 03:38 AM
Re: When is it an online "application"?
Richard Insley
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10K Club
Joined: Oct 2000
Posts: 27,763
On the Net
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Perhaps you can say this is a prequal and they should click the Submit button just to avoid confusion.
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AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#1253929 - 09/21/09 07:07 PM
Re: When is it an online "application"?
Richard Insley
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100 Club
Joined: Nov 2004
Posts: 237
USA
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In the applicant's mind, it's an application the second s/he clicks the button labeled "Apply Now". Richard, this is your opinion, right, and not based on any regulation? I'm not sure I agree.
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#1253936 - 09/21/09 07:10 PM
Re: When is it an online "application"?
Amos
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10K Club
Joined: Jul 2001
Posts: 84,371
Galveston, TX
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What type of loan application are we talking about?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1253984 - 09/21/09 07:46 PM
Re: When is it an online "application"?
rlcarey
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Diamond Poster
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
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What part of "Apply Now" don't you understand?
The only out I can think of is if you have a disclaimer on the next page that they must provide all requested information and hit "submit" to complete the process and that failure to submit will abort the process without the application being submitted.
Al
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Al Miller, CRCM Opinions expressed are my own and not necessarily shared by my employer.
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#1254214 - 09/22/09 03:55 AM
Re: When is it an online "application"?
Amos
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10K Club
Joined: Oct 2000
Posts: 10,204
Toano, VA
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Richard, this is your opinion, right, and not based on any regulation? I'm not sure I agree. No regulation specifically addresses the act of clicking a button, but I'll be interested in how you're reading Section 202.2(f) ( Application means an oral or written request for an extension of credit that is made in accordance with procedures used by a creditor for the type of credit requested.) and concluding that: a. the borrower is not requesting an extension of credit, or b. the lender's web site is not one of the lender's procedures for receiving credit requests.
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#1254291 - 09/22/09 01:16 PM
Re: When is it an online "application"?
Richard Insley
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100 Club
Joined: Nov 2004
Posts: 237
USA
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Richard, this is your opinion, right, and not based on any regulation? I'm not sure I agree. No regulation specifically addresses the act of clicking a button, but I'll be interested in how you're reading Section 202.2(f) ( Application means an oral or written request for an extension of credit that is made in accordance with procedures used by a creditor for the type of credit requested.) and concluding that: a. the borrower is not requesting an extension of credit, or b. the lender's web site is not one of the lender's procedures for receiving credit requests. I am saying that starting an online application does not necessarily mean that the lender has received an application. WIth the online application system that I am familiar with, the consumer must click on the submit button before it is considered an "application." If the consumer partially completes the online application screens and then stops and never comes back to finish the app and submit it, then it's not considered an application.
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#1254470 - 09/22/09 03:14 PM
Re: When is it an online "application"?
Amos
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10K Club
Joined: Oct 2000
Posts: 10,204
Toano, VA
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the consumer must click on the submit button before it is considered an "application." Yes, no question that there's no request for credit until the applicant knowingly submits a request. If a system supports what I would call an "in progress" application, there's no application until the applicant is satisfied that all requested data is in place and then clicks whatever button or link necessary to transmit the completed e-form. This is comparable to applicants who work on paper application forms at home and only submit them when all the blanks are filled. Why not just change what the button says? It is an easy change to make. I doubt you're suggesting an "I am not a duck" sham, but other than "application", what else can you call an online form that purports to be the first step in obtaining a loan?
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#1254602 - 09/22/09 05:02 PM
Re: When is it an online "application"?
Kathleen O. Blanchard
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10K Club
Joined: Oct 2000
Posts: 10,204
Toano, VA
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Yes, KB, I agree. I'm assuming that a form ending with a button labeled "apply now" requests credit information & I shouldn't jump the that conclusion. If the form is there to source casual inquiries, however, "apply now" is a poor choice of labels for the action button.
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