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#2260288 - 09/27/21 05:28 PM CHARM and Heloc brochure
Auditor16 Offline
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Joined: Jan 2018
Posts: 22
For the CHARM and HELOC brochure, are these required when only scenarios are provided to the consumer (in person)? I understand that the regulation notes "at the time an application is provided to the consumer," however, I read in an older post that if a consumer shows interest (not that an application was provided), then the brochure(s) should be provided to them at that time (if in person) because they are considered shopping disclosures. I wanted to confirm as I was confused on the last part.

Thank you!

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#2260291 - 09/27/21 05:52 PM Re: CHARM and Heloc brochure Auditor16
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,238
Galveston, TX
They are required at application. Can you give them at other times - sure. That is up to you, but why not?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2260294 - 09/27/21 06:14 PM Re: CHARM and Heloc brochure Auditor16
Auditor16 Offline
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Joined: Jan 2018
Posts: 22
Thank you!

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