We are implementing a new online loan origination software. In viewing the demo's I am not seeing a checkbox anywhere or any other method to demonstrate joint intent. The business unit is asking if the final application that is sent to the customer via Docusign would suffice.
I am thinking that would not suffice as the rule indicates it must be documented at the time of the application.
The definitions define an application as "means an oral or written request for an extension of credit that is made in accordance with procedures used by a creditor for the type of credit requested. The term application does not include the use of an account or line of credit to obtain an amount of credit that is within a previously established credit limit. A completed application means an application in connection with which a creditor has received all the information that the creditor regularly obtains and considers in evaluating applications for the amount and type of credit requested (including, but not limited to, credit reports, any additional information requested from the applicant, and any approvals or reports by governmental agencies or other persons that are necessary to guarantee, insure, or provide security for the credit or collateral). The creditor shall exercise reasonable diligence in obtaining such information."
Since the online application meets the rules definition of application, is the document sent over via docusign later in the process too late to obtain joint intent?