Currently our LO will issue the LE usually with a floating rate and then a few days later the borrower decides to lock in a rate and the LO will issue a revised LE. This normally occurs after a phone conversation with the borrower. Just like the Intent to Proceed can be given verbally, we have approved the CIC request to be given verbally. An outside compliance audit company is asking where our written documentation is from the borrower requesting the CIC. Does anyone require written request from the borrower in a situation like this or know if this is a requirment? I was in system admin but recently moved over to Compliance and still learning the ropes. Thanks

Read this. There are also numerous threads in this forum that discuss the need for a signed written rate lock agreement before you can redisclose an LE marked 'yes' to rate lock.

I agree with the written rate lock being needed. I think the concern for accepting a verbal CIC is that you only have 3 days from learning of a valid CIC to reissue the LE and if it is not documented anywhere, then there is no way to tell when the information was received.

I agree with the written rate lock. We start with a verbal approval of the rate by the borrower, document the loan notes, with the requirement that the signed rate lock has to be provided within 24 hours. Also look for guidance in your state law, as it may list the required information that needs to be in your rate lock agreement.

Agree with above. The auditors are concerned about knowing the date of the Changed circumstance to determine if you disclosed in time and if you were able to change fees.

Also without an agreement you cant mark as locked (which everyone else said)>

You can 'lock' the rate with the borrower at any time.
But the CIC clock doesn't start until you have the signed rate lock agreement in hand.
Example: On Monday, Borrower calls and indicates they want to lock today's rate. But they cannot come in to the bank to sign the agreement today. They come in on Friday and sign as does your LO. Friday is the start of the CIC clock for the rate lock. The LE marked 'yes' to rate lock must be delivered by the following Tuesday. (or Wednesday if Saturday isn't a business day for you.)