We take online home equity line of credit applications. I was asked if we could provide a link to the CFPB website for applicants to print off their own homeownership counseling list instead of us providing it within 3 days of receiving the online application.

Can we provide a link during the online application process for applicants to print their own list? Or, must the bank provide the list within 3 days of receiving the application?

Thanks.

I've read the link & have a follow-up question.

I don't think we have any intention of working with a software vendor to generate the list. I think management would like to put a link on the website & have the applicants generate their own list.

From reading the link, I don't think putting the link on the website for the applicants to generate their own list is OK.

Am I correct?

Thanks.

You are correct. Even if you were in the development stage of creating the list, you still have to "deliver" a disclosure providing them the link. You could not just "put a link on the website".