One way to address it is to have a special authorization form used for these borrowers that sets out the pros and cons, and make sure each customer gets a copy of his her authorization with that info on it (the copy is required by Reg E §1005.10(b). Be sure to include on the form instructions on how to cancel the authorization.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8