QUESTION: Does "at the time of application" mean when you actually give a consumer an application or when the consumer
actually turns the application in for credit?
ANSWER: This can depend on the regulation. In the traditional consumer and real estate loan, it means when you receive a
completed application. You have some control over this based on your policy, practices and what is in the requirements. For real estate, as an example, the property should be identified. Without that you could consider it a prequalification.
The new insurance disclosure rules taking effect October 1 may be looked at differently since disclosures are triggered differently and are dependent on the offer of insurance. This is new to all of us.
Internet applications will fall under the same rules above.
BankersOnline is a free service made possible by the generous support of our
advertisers and sponsors. Advertisers and sponsors are not responsible for site content. Please help us keep BankersOnline FREE to all
banking professionals. Support our advertisers and sponsors by clicking
through to learn more about their products and services.
Print Friendly!
Email This Article!
Discuss NOW!
