Reg B says we need a written application on a loan for the purchase of a primary residence. In an effort to be efficient (or lazy) a LO just copied the app of a customer from a previous investment purchase of a month prior. The LO used white out on the items that were different (ie dates, loan amount, purpose, address, etc.) I don't think this is kosher, but I'd like a second opinion.

If this new app requires GMI, the customer has to be given the opportunity first to furnish that. Next you'll use visual observation. Neither of those should have been on the last app. Are you using a separate sheet? That would be fine for that data collection. And so long as the customer re-acknowledges the other info, I am fine with it being filled out for them in advance. But it also has to meet your requirements for the loan type being requested.

Both loans required GMI. The original loan was a purchase of investment property. The loan in question was for the purchase of the primary residence. Incidentally the customer is a real estate agent and appraiser. We make 10-20 purchase or home improvement loans for this customer every year. The LO was trying to make things as quick and painless for the customer (and himself) as possible.