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#1241887 - 08/28/09 11:09 PM When is it an online "application"?
Zuki Offline
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Zuki
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Pacific Northwest
If a bank's website has an option to click "Apply Now" to submit personal information with regard to applying for a loan, is the following statement enough to consider it NOT to be an application until the customer is called back?

"To begin, please fill out the fields in the form below. One of our representatives will contact you within one business day to complete the process."

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eBanking / Technology
#1241900 - 08/29/09 12:38 AM Re: When is it an online "application"? Zuki
Richard Insley Offline
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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
Andy_Z Offline
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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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#1253929 - 09/21/09 07:07 PM Re: When is it an online "application"? Richard Insley
Amos Offline
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Originally Posted By: Richard Insley
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
rlcarey Online
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What type of loan application are we talking about?
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#1253984 - 09/21/09 07:46 PM Re: When is it an online "application"? rlcarey
Al Miller Offline
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Pleasanton CA USA
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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#1254214 - 09/22/09 03:55 AM Re: When is it an online "application"? Amos
Richard Insley Offline
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Originally Posted By: Amos
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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#1254238 - 09/22/09 12:24 PM Re: When is it an online "application"? Richard Insley
Kathleen O. Blanchard Offline

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Why not just change what the button says? It is an easy change to make.
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#1254291 - 09/22/09 01:16 PM Re: When is it an online "application"? Richard Insley
Amos Offline
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Originally Posted By: Richard Insley
Originally Posted By: Amos
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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#1254300 - 09/22/09 01:22 PM Re: When is it an online "application"? Amos
Kathleen O. Blanchard Offline

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What you are describing is pretty typical of true online aps. In the case described in the original question it seems that this is not really an online ap, but a basic info gathering followed up by personal contact.

In that case, it makes sense to clarify the customer is not really "applying" but letting the bank know they wish to be contact to apply. Of course, just how much info is requested after selecting "apply now" will determine the actual situation.
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#1254470 - 09/22/09 03:14 PM Re: When is it an online "application"? Amos
Richard Insley Offline
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Originally Posted By: Amos
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.

Originally Posted By: MS Kaybee
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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#1254592 - 09/22/09 04:53 PM Re: When is it an online "application"? Richard Insley
Kathleen O. Blanchard Offline

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A button that lets you provide basic contact info so a bank rep can call and take your application. It depends upon what the poster means by "Personal Information".
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#1254602 - 09/22/09 05:02 PM Re: When is it an online "application"? Kathleen O. Blanchard
Richard Insley Offline
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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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#1254611 - 09/22/09 05:06 PM Re: When is it an online "application"? Richard Insley
Kathleen O. Blanchard Offline

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It may very well. I have seen links on bank sites where it says apply and then it takes you to a contact form.

Well, the original poster can read this thread and make some decisions. Either it is a real ap and needs to be treated as such or it is an initial contact point and should be labelled and treated as such.
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