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#12053 - 09/08/01 04:46 AM Electronic Declinations
Jim Huertas Offline
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Joined: Sep 2001
Posts: 2
Billings, MT
Does anyone have any thoughts/comments/knowledge on electronic declinations for online loan applications? I realize that the state will have to adopt this as well (e-sign act), but is anyone doing it yet? Does the fed recognize it?
Can it be done?

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Jim Huertas
President
Crytech, LLC

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Jim Huertas President Crytech, LLC

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eBanking / Technology
#12054 - 09/07/01 10:38 PM Re: Electronic Declinations
Andy_Z Offline
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Posts: 27,748
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Everyone focuses on E-sign. More than half the states have adopted UETA. Watch for that.

I haven't heard of anyone doing e-declines but they could. The hardest part would be the proper FCRA disclosures and content (reasons) to the joint applicants.

If the system isn't automated, maybe that would work well if you have demonstrable consent and have met the other e-sign/UETA requirements.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

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#12055 - 09/09/01 09:07 PM Re: Electronic Declinations
Richard Insley Online
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Richard Insley
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Posts: 10,179
Toano, VA
e-Adverse action notices will require an ESIGN disclosure & opt-in. As a practical matter, you'll need to get the customer's consent at the time you take the e-app.
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#12056 - 09/10/01 02:35 PM Re: Electronic Declinations
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Think carefully about this: Do you want to be sending AA notices to applicants via non-secured e-mail?
These messages will contain at minimum words to the effect:
quote:
Dear Mr. Public: We cannot approve your recent request for a new car loan. Please contact us [method] within [days] to receive the specific reasons for our decision.

And, of course, you'll undoubtedly be including the FCRA notice and credit bureau information. Sound like some automation needs here, if you want to send e-mail with the bad news.
Alternative, perhaps? Send an e-mail message inviting the customer to log into your secure Web site where he/she will learn the bad news privately.
Of course, all of this is predicated on your having obtained e-sign approval from the customer to deal with him/her electronically.
This could be a solution in search of a problem.
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