I've seen both the HELOC Important Terms/Brochure and the ARM Disclosure/CHARM booklet referred to as "shopping disclosures" in other threads, to differentiate them from post-application disclosures. I like the term, but don't remember who coined it. My apologies for not giving proper credit.
Anyway, I've finally convinced the business line that: (1) yes, we have to give the shopping disclosures out as soon as we know a prospective customer is interested in one of those products; and (2) no, including it in the initial disclosure packet after application is not enough (although we're going to keep doing that as a possible cure if an LO fails to provide the shopping disclosures as required). We're in the process of adding the shopping disclosures to our on-line application portal, so...progress!
My question for those willing to share is: how/when are you delivering the shopping disclosures to customers that come in via something other than your on-line application portal? And for those of you who aren't able to deliver/track those shopping disclosures through your mortgage processing platform due to the pre-application delivery timing: are you keeping any records to establish the delivery of the shopping disclosures, or are you relying on just your written procedure/training?
Thank you in advance for being willing to share.