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#2219527 - 08/12/19 03:51 PM Remove Demographic Info from Online Application?
Tarhe Offline
Diamond Poster
Joined: Nov 2006
Posts: 1,409
California
Our NEW mortgage manager would like to remove the borrower demographic information section from our online application in order to make the online process less cumbersome for applicants. The demographic information would then be completed when the MLO interviews the applicant. The online application is not a complete application - and the thought is that it would be easier to collect this information when collecting the other missing information for the 1003.

My reaction is to say NO, that we leave the demographic information there - especially if the application is then withdrawn or other adverse action takes place and this is our only chance to obtain it.

Do others separate it out this way??

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Lending Compliance
#2219530 - 08/12/19 04:13 PM Re: Remove Demographic Info from Online Application? Tarhe
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
IMHO - They should quickly become your OLD mortgage manager. smile
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#2219549 - 08/12/19 05:54 PM Re: Remove Demographic Info from Online Application? rlcarey
Truffle Royale Offline

10K Club
Joined: Jul 2003
Posts: 17,400
Quote
The online application is not a complete application

I'm curious about this statement.
Are you taking applications online or just getting perquals or what?

fwiw, no bank I know of segregates the DMI out when taking online applications. But that brings me back around to my questoin above. ??

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#2219559 - 08/12/19 06:52 PM Re: Remove Demographic Info from Online Application? Tarhe
Tarhe Offline
Diamond Poster
Joined: Nov 2006
Posts: 1,409
California
We are launching Ellie Mae's Consumer Connect and the Manager wants to streamline the online process for the applicant - such as by removing the declarations and the demographic section - because the "intent" is that the MLO will then contact the applicant within 2 business days to complete the rest of the application via telephone or in-person. So, it will not include everything in the 1003. Evidently the only thing that will be "required" for the applicant to complete is name and email address before they hit "Submit". It is not a Prequal (because we do not do prequalifications). Supposedly, the applicant can complete as much (or as little) as he wants and Submit - and the MLO will contact the applicant and finish it up - but it could be a couple of business days before that happens.

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#2219731 - 08/14/19 05:36 PM Re: Remove Demographic Info from Online Application? Tarhe
Truffle Royale Offline

10K Club
Joined: Jul 2003
Posts: 17,400
imho, your Manager is taking you down a dangerous road. The suggestion to remove parts of the application 'to streamline for the applicant' may come under scrutiny by examiners for being a way to skirt around TRID, HMDA and other Reg requirements. This article is worth the time to read.

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#2219754 - 08/14/19 09:34 PM Re: Remove Demographic Info from Online Application? Tarhe
Tarhe Offline
Diamond Poster
Joined: Nov 2006
Posts: 1,409
California
Thank you very much!!

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