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#638199 - 11/14/06 08:55 PM Application available online v. "apply online"
Patsy Cline Offline
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Patsy Cline
Joined: Sep 2002
Posts: 1,117
On the road...
Our lenders want to make a few of our applications available online in PDF format. No specific reference to a loan product other than "click here" for a HELOC application, "click here" for a mortgage application, "click here" for a consumer loan application. My initial thought was that this still requires the necessary "at application" disclosures... but now I am second guessing myself. This is not really "applying online". Would this require "at application" disclosures?
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Michelle CRCM

"What would you attempt to do if you knew you could not fail?" ~ unknown


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eBanking / Technology
#638200 - 11/14/06 10:06 PM Re: Application available online v. "apply online"
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 10,179
Toano, VA
Quote:

"at application" disclosures



Reread the regulation. You're generalizing a rule that is more precise.
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#638201 - 11/15/06 04:51 AM Re: Application available online v. "apply online"
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Keep in mind that the HELOC booklet and program disclosure are required to be provided to the applicant when the application is provided. Refer to 226.5b(b). Since you will be providing an application, you will trigger these disclosures. How will you provide them?
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David Dickinson
http://www.bankerscompliance.com

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