Our lenders have come up with some new "customer friendly" ideas. One of these would be to go to the applicant, with a laptop, to complete the application process. It sounds like the cust. would initiate the process by calling us and after some initial phone information, we go to them to get all the details and additional info. This feels close to branching violation, but maybe I am being too conservative.

Is anyone else doing this? Does anyone think it would be a violation?

In advance, thanks.

My understanding is that it's not where the application is taken, but where the credit decision is made. The bigger question would be - do your lenders remember the standard disclosures, particularly USA PATRIOT Act?
I too, would be interested in an informed answer to this question, as our bank as well as others have taken applications at business fairs, expos, customers offices, etc -

I would prefer to do it over the phone or Web before using the time needed to travel, scan documents for copies and accept the risks of going off-site if this is to a persons home. (The risks are both to your employee being harmed and the customer claiming to have been.)

But it shouldn't violate branching requirements if no deposits are accepted or monies lent at that location.

Some state laws may apply if you were at a fair for example, and this was considered an LPO. You may technically need an approval for that.

A portable printer may also be needed to get signatures on documents and to provide any necessary disclosures for ARMs, CHARMs, RESPA, etc. (any disclosures you would customarily provide at application).

Thanks for the input, I feel better now. So far it seems that this branch is located in a very metro area and the loan officers were speaking in terms of going to the customer's office. But, you have given me some more good talking points--thanks.

Soccermom, originators have been doing this for years. Most lenders have the proper software loaded on the laptops provided to the originators. The originators take the application and print out all of the origination disclosures right in front of the applicants. They can even run credit reports and submit the applications to LP and DU. The savings and loan I was with from 1990 to 2001 was providing originators with laptops and portable printers to do this. The originators didn't even have to come into the office every day. They could obtain their current rates via the computers each morning. This gave them more time to concentrate on originating loans, which was what they were being paid to do. They were also required to deliver the GFE, TIL, and ARM Disclosures, plus the Possible Transfer of Servicing Disclosure at time of application. Their disclosures and forms were set up in document sets, so nothing would be missed. I know. I set up the document sets.

The first thing the processor did after receiving the file was to check it for missing items. If the originator was missing a required disclosure, they had to obtain the disclosure before the file was put into processing.

Of course, this was in Atlanta. And, I believe we were ahead of the curve in technology. But, it worked. The builders and the realtors were really impressed.