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#1740068 - 09/12/12 01:54 PM Lending Disclosures
Indy Banker Offline
Platinum Poster
Joined: Aug 2010
Posts: 528
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.

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Lending Compliance
#1740083 - 09/12/12 02:24 PM Re: Lending Disclosures Indy Banker
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,016
Bloomington, IN
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.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1740179 - 09/12/12 04:57 PM Re: Lending Disclosures Indy Banker
Indy Banker Offline
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Joined: Aug 2010
Posts: 528
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.

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#1740187 - 09/12/12 05:06 PM Re: Lending Disclosures Indy Banker
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
We include HELOC disclosures with the application....if we had an ARM(s) program(s), we would do the same.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#1779596 - 01/24/13 07:59 PM Re: Lending Disclosures Indy Banker
Sugarbaker Offline
Gold Star
Joined: Nov 2005
Posts: 265
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?

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