You are required to maintain written applications under Regulation B for certain transactions, but in practicality, if you don't maintain records of a home loan application in one form or another, how could you ever prove your HMDA reporting data is correct?
1002.4(c) Written applications. A creditor shall take written applications for the dwelling-related types of credit covered by §1002.13(a).
1. Requirement for written applications. Model application forms are provided in Appendix B to the regulation, although use of a printed form is not required. A creditor will satisfy the requirement by writing down the information that it normally considers in making a credit decision. The creditor may complete an application on behalf of an applicant and need not require the applicant to sign the application.
2. Telephone applications. A creditor that accepts applications by telephone for dwelling-related credit covered by §1002.13 can meet the requirement for written applications by writing down pertinent information that is provided by the applicant.
3. Computerized entry. Information entered directly into and retained by a computerized system qualifies as a written application under this paragraph. (See the commentary to §1002.13(b), Applications through electronic media and Applications through video. )
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