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#1686875 - 04/09/12 03:00 PM General Application on Website
getinfo Offline
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Joined: May 2011
Posts: 19
We are considering providing a general application that can be used for Personal Secured and Unsecured (Term, LOC and ODP), Auto, and Home Equity (Term and LOC)where the customer would print it and either mail, fax or walk it into one of the branches. Do we need to provide any initial disclosures on the website?

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#1686919 - 04/09/12 03:59 PM Re: General Application on Website getinfo
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 10,204
Toano, VA
Sure. You have to provide all the pre-application disclosures that might apply to any and all of the products for which the "general" form would apply.
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#1686924 - 04/09/12 04:09 PM Re: General Application on Website getinfo
Comply Wren Offline
Member
Joined: Dec 2009
Posts: 72
In addition to any required application disclosures, you have to be very careful in crafting a general application so that you don't run afoul of the ECOA. I would review Regulation B (especially section 1002.5) very carefully.

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