I think you could have an arguement that the online "applications" are just inquiries and not applications.
And by what section of Regulation B do you rest that opinion on?
If we receive an online mortgage application for a mobile home and we don't lend on mobile homes, are we required to give the borrower an adverse action notice
Mobile homes are not a type of credit offered, they are a type of collateral offered. You make the type of loan being applied for, residential lending, you just don't make residential loans secured by mobile homes.
On that same line, we receive a number of online applications where the borrowers are just shopping around to different lenders and don't really intend to go with us, do we need to give them adverse action notices and, if so, for what reason?
If they are shopping then how do you know they have no intentions of going with you simply from the information on the application?
If you accept Internet applications then I think you are going to be hard pressed not to treat all such applications, or any written application for that matter, as an application under Reg. B. For those that are incomplete send an AAN denying it for an incomplete application or send them the notice of incompleteness.
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The opinions expressed are mine and they are not to be taken as legal advice.