If a loan application is taken over the phone (only done for customers with an ongoing banking relationship) and the customers indicate the joint intent to apply orally; can this be documented in writing at a subsequent time. For instance, at the first face to face meeting between the LO and customers (which in some cases is at closing)?

Has to be done "at application."

Why doesn't the LO ask & notate the app during the phone conversation?

Right. This can be documented by the LO in a note to the file on what transpired during call. If your bank's policy/procedure says that a form must be signed by the customer it might be good to amend that to accommodate for these situations because the law does not say it has to be written by the customer.

Well, the LO will complete the application for the customer and will indicate the app was taken by phone. The applicant sections of the app will be completed on each person jointly applying.

We currently have the intent to apply for joint credit language on the app that the customer can initial.

Should I add language to the app so that the LO can acknowledge that each person agreed to jointly apply for credit to use in the event of a phone app?

Our phone applications are taken and entered directly into the application system. The Call Center staff are instructed to speak directly with all parties who wish to apply (course there's no way to make sure of who they're talking to.....so this method is just a good faith effort) and then document each applicant's response to the question with a notation of "verified by phone."

I do think that at closing, the joint applicants are asked to go ahead and initial the printed application. We've not been criticized for doing that.

Swiggles, that is the same procedure that I think I will institute. Thank you all for the information.

We participate in indirect lending with several car dealerships, we get application after the customer has come and gone from the dealership, the application is joint as evidenced from both signatures on the application and the joint acknowledgement is checked however they did not initial the joint acknowledgement, what now?