Need some input, please. Our bank has traditionally had MLO's generate and disclose all required disclosures (early T/L, GFE, etc.) at the time of application interview with their borrowers. We are considering going to central processing of all regulatory disclosures, to be mailed out from the lending center to borrowers within required time-frames. Seems to make sense, especially in light of all the changes coming next year. One thing we're stumped on - the ARM program disclosure has to be provided when the application form is provided (assume that means when the MLO interviews the borrowers or "takes" the application" in a face-to-face setting) so how does a central processing system handle the ARM program disclosure requirements? Should we just arm the MLO with hard copy ARM disclosures that they can give the borrower, along with the CHARM booklet, at time of face-to-face meeting? Interested to know how those with central disclosure processing handle this.

so how does a central processing system handle the ARM program disclosure requirements?

They can't unless your applications are submitted by the consumer by mail or telephone.

Yes, that was our understanding. Sorta undermines the benefit of a central processing system for disclosures to a certain extent. Our thoughts were to have all the ARM program disclosures pre-printed for the LO and insert them into the CHARM booklet, so he/she can provide at the interview. Thanks for the response.

We include HELOC disclosures with the application....if we had an ARM(s) program(s), we would do the same.

Do you give disclosure for each type of ARM at application (e.g. is the customer getting a copy of your 1/1,3/1 and 5/1 along with the application) or can we just give one of the ARM disclosures even if we aren't sure which ARM program they will go with?