1- yes
2- It can be done this way...or if the application is just available for the consumer to print and then bring in to the loan office, it could be done at that time, or by closing.
I'd have to go back and look, but if memory serves me it will depend on your particular policy of sharing information and whether it involves all consumers or only customers. If the later, then I'm thinking it's not required until that customer relationship is actually established. In other words, if the loan is declined, the may never be a customer, just a consumer.
Oh boy..I need to go back and read ours...we don't share, so we fall in the later group, but I need a refresher. It's funny..seems like once you establish procedures, you kinda get lax on the fine points until you go back to review again!
I went back and looked and will stand by the above statement!