Can we remove one of the six fields required under RESPA to avoid tripping the application online? Management wants to reduce the number of online applications that come from internet surfers. Our vendor states that many of their clients do this. I'm concerned this may be viewed as circumventing the regulations. Thoughts?

How do other lenders reduce/avoid surfer applications?

We removed one of the six fields and haven't had a problem with examiners. I don't think we have a field for estimated value of current property, but I wouldn't quote me on that.

So...we have a new version of an internet application and we have included all six fields. However, we are not requesting a loan term. This is the only other piece of information that we require in order to have an application. Do you think examiners will have a problem with this? My understanding is that once the application is received, the mortgage originator will contact the applicant to discuss loan products and terms and will then issue the early disclosures. I'm just not sure that I am comfortable with this process. Thank you!

2nd anon: Do you offer a lot of loan terms? If it is just 1 or 2 (as in, the lender can proceed with a credit decision for either 30 yr or 15 yr), I agree that this move is kind of transparent. A safer bet: property address, or property value. Something that would TRULY require the originator to contact the applicant in order to make a credit decision.

Our internet applications are just for secondary market loans and we have always requested all 6 pieces of information and also the loan term. Research that I am doing elsewhere on this concurs with my thoughts that not asking for the information is not in the spirit of the law and would not be looked favorably upon by examiners. Was just curious if this is really what the majority of banks do (not ask for certain information) as I just can’t get comfortable with this process.

I agree with you. I have not seen an on-line application system that purposely leaves off one item and then say - sorry, this is not a RESPA application.

2nd anon: Our system asks for one too few pieces of info. One justification is that we want to be able to have a conversation with the applicant before pulling credit.

Justify it all you want too.........

During that "conversation" there is a tremendous amount of risk that the MLO will discourage the applicant from moving forward. The process you describe is... as my dad always used to say... "just asking for trouble" !

2nd anon - True that. But hey, at least it's hard to compare closed loans to denied loans when you have no denied loans, lolz.