If I understand the electronic disclosure section of Reg Z, the ARM program application disclosure and the CHARM booklet must be provided with the online mortgage application form. But what if the online process starts with a request for prequalification? Do we need to give the ARM program disclosure and CHARM online when they fill out the online prequalification request form, or can we send it out to the customer once they move past prequalification and decide to move forward with an application?
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Any statements or opinions are mine, not necessarily my employer's.