Skip to content
BOL Conferences
Thread Options
#2239315 - 07/09/20 02:25 PM Delivery of "Shopping Disclosures"
Learned Hand Offline
Junior Member
Joined: Feb 2019
Posts: 40
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.

Return to Top
Lending Compliance
#2239354 - 07/09/20 06:45 PM Re: Delivery of "Shopping Disclosures" Learned Hand
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
We include the disclosures and booklets in the application packet provided to the consumer. If the application packet is completed in person then the loan officer provides the disclosure to the consumer at that time.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top

Moderator:  Andy_Z