applications received at a branch, then forwards the application to our loan operations for processing. Customer does currently receive an application disclosure at the time the application is submitted.
The way this is written leads me to believe your procedures are not compliant with providing the disclosures. The regulation requires you to provide the disclosure at the time you provide the application to the consumer, not when they submit an application. 1026.40(b).
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The opinions expressed are mine and they are not to be taken as legal advice.