We offer a VISA credit card product ( both business and consumer)online. The consumer or business downloads an application form which they then mail or bring into a local branch. The bank has not included any of the required disclosures under 226.5(a)items 1-7 i.e. rate fee variable etc. that you ordinarily see in table format on a take-one application. Is this a problem? The thought process was that as this is a customer request it would fall under one of the exceptions.. this goes against everything I have done in the past.. I'd appreciate your thoughts.

I would consider an application that is made available on your Web site as a "take one" application and the applicable disclosures under 226.5a(e) would apply.