I found out today that several of our lenders are not giving out the Notice to the Home Loan Applicant and the Disclosure of Credit Score Information. Apparently they think that just because we do not keep a copy of this, that you don't have to do it! Has anyone required their lenders to keep a copy of them just to prove that they gave it to the customer? Any other suggestions?

Our requirement is to have the loan officers initial and date a copy to keep in the file as proof of mailing.

We have our customers sign the form to acknowledge receipt and then retain a copy for file imaging.

In a recent audit, it also appears that our loan officers are not giving out the notice - or if they are, there is no evidence or notation in the file to show that they did. Are we obligated to go back and send the disclosures to the customers at this time in order to correct our oversight? Or is that not required as long as we correct our process going forward? Thank you!

I have to agree with Dan on this. The first thing the examiners asked me about during an audit a few months ago was the Notice to Home Loan Applicants. This is an unacceptable way of handling this situation. A copy of this form should be in the credit file.

We keep a copy of all documents the customer receives in the customers credit file.