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?