Our call center, which is not a loan call center is receiving calls from people who want to apply for a loan. The representative, instead of directing them to the website to apply for themselves or to someone with access to the loan system is going onto the website as if they were the applicant and accepting the electronic disclosures as if they were the applicant. I am very concerned about this as the applicant is not the one clicking in the box acknowleging I John Doe agree to the terms and conditions...

Thoughts?

Your customers aren't getting their disclosures as required. PLUS there may be a SAFE Act issue if the call rep is discussing rates or terms.

I'd stop this immediately.

I wonder how many GFEs have not been properly provided due to this. For every loan processed this way you technically owe the borrower 100% cures for the closing fees since a GFE was not properly provided.

Safe act because they are not a loan officer (NMLS) ?

SAFE Act because they are not licensed, yes. Not required to be a loan officer to be licensed/certified but required to be licensed/certified to discuss mortgage terms and I would think a term discussion would HAVE to be part of completing an application.