The phrase "negotiate the terms of a loan" is unfortunately not defined, so it's up to each shop to determine how much risk they want to take. Or put another way, how do you draw a clear bright line so your staff know whether they've crossed over into "negotiation"?
Last edited by Way Out West; 07/19/10 10:42 PM.
In a previous life, we determined that providing general info about loan products, terms and pricing was OK, not "negotiating." Also, a loan officer could describe the loan application process, what documentation might be required, etc. But if you moved over into discussing the customer's specific situation or needs, how much he or she wanted to borrow, or if you proceeded to take an application, you were definitely "negotiating" -- which all had to be done in English.
From my perspective, I would say "sitting down to sign the loan agreement and receive disclosures" is way over the line into negotiating. Remember, the foreign language disclosure one is supposed to provide it a GFE, which comes pretty early in the process.
The opinions expressed are mine and not those of my employer