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Is a Downloaded App Electronic
Answer by Andy Zavoina, BOL Guru
Guru Bio
Question: If we have customers download and print a loan application that is mailed back in, do rules concerning electronic delivery apply here?
Answer: No. You have used the electronic media in place of the post office to deliver an application. You are not collecting any information with your web site or email app, and by making a generic application available there are no disclosures that must accompany the application, unless you are offering specifically an ARM, as an example. In that case the CHARM booklet and program disclosures would have to accompany the application.
First published on BankersOnline.com 4/21/08
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