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#1248689 - 09/11/09 02:59 PM Internet App Vs. Telephone App
HMDA is my life Offline
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HMDA is my life
Joined: Nov 2006
Posts: 64
Montana
Our business practice is to call customers who do not "submit" the internet application on our mtg website. The website administrator will assign a lender to the incomplete application if the customer for whatever reason decides to quit in the process. The assigned lender then calls the customer to see if they truly want to proceed with the application. Two questions come to mind. 1. If a borrower started an application on the internet and it was clarified and completed by telephone, it the method of app received internet or telephone? 2. When the customer indicates that they don't want to go through with the loan when the lender calls in the above situation, are those applications HMDA reportable?

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#1248779 - 09/11/09 04:05 PM Re: Internet App Vs. Telephone App HMDA is my life
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
1. Telephone.
2. It depends. Do you have an application that was withdrawn (did you have enough info to call it an application)?
or was it an inquiry and then never turned into an application?
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#1344692 - 02/17/10 06:51 PM Re: Internet App Vs. Telephone App David Dickinson
Lissa P. Offline
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Joined: Oct 2003
Posts: 474
Texas, USA
Different twist here that I need help with... we frequently get Internet applications where we are unable to contact the applicant for more information. (they won't return phone calls, etc.) In these cases, we never even evaluate their credit. So, do we consider these as inquiries that are not HMDA reportable? Or do we report them as applications that were withdrawn? I hesitate to say "incomplete" because the lenders never sent a written notice of incompleteness.

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#1345667 - 02/18/10 08:44 PM Re: Internet App Vs. Telephone App Lissa P.
Brock Offline
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Brock
Joined: Feb 2010
Posts: 217
Columbia, MO
When you say internet applications do you mean that all the 1003 data is submitted over the internet? If that is not the case and you don't get all 1003 data, the loan is not reportable. If it is the other way around, I too would like an answer.

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#1345760 - 02/18/10 10:00 PM Re: Internet App Vs. Telephone App Brock
hmdagal Offline
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hmdagal
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Posts: 3,841
I don't understand why you need to contact the applicant? Does your system let them submit an internet application that is only partially completed?

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#1346036 - 02/19/10 03:37 PM Re: Internet App Vs. Telephone App hmdagal
Lissa P. Offline
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Joined: Oct 2003
Posts: 474
Texas, USA
No, it's not the full 1003... it's a shortened application that supplies the basics. If the request is "approved" then a full 1003 is forwarded to the applicant for completion.

The applicant is usually contacted to verify that they are not actually trying to refi a Home Equity lien, etc.

So, Brock are you saying that we wouldn't need to report the application since it's not the full 1003? Guess I've missed the boat on that one!

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#1346072 - 02/19/10 03:57 PM Re: Internet App Vs. Telephone App Lissa P.
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Quote:
So, Brock are you saying that we wouldn't need to report the application since it's not the full 1003? Guess I've missed the boat on that one!


No you missed nothing. Whether the request is on a napkin or a 1003 it's still an application if you have all the necessary information.

Here's my take on Internet applications:

1. If your application program allows them to "submit" the application without all necessary information then:

a. Purchase request - if you don't have all 6 pieces of information you don't have an app for RESPA disclosures but you would have an incomplete application for Reg B and must either deny the application for being incomplete or send the notice of incompleteness. Calling them requesting the information and them not providing the information is not IMO a withdrawal. You won't process the application without the information so if they don't provide the information you're not going to process the request, IOWs you're denying the request due to the missing information.

b. Refinances - you may not have all the required information for RESPA but more than likely you will have the necessary information that would make it subject to HMDA plus the above comments concerning Reg. B.


Not sure why wanting to refinance a home equity lien has anything to do with you having an application. The only thing that may affect is which department would process the request.


PS. If you didn't pick up on it, I'm not a big Internet application fan for mortgage loans. I view them as a necessary evil!!!
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#1346216 - 02/19/10 06:00 PM Re: Internet App Vs. Telephone App Dan Persfull
Lissa P. Offline
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Joined: Oct 2003
Posts: 474
Texas, USA
[quote=Dan PersfullNot sure why wanting to refinance a home equity lien has anything to do with you having an application. The only thing that may affect is which department would process the request.


PS. If you didn't pick up on it, I'm not a big Internet application fan for mortgage loans. I view them as a necessary evil!!![/quote]


Thanks Dan! I agree with everything you said. I think we have had a failure to provide due diligence in processing these requests.

FWIW-In Texas there are additional specific disclosures that have to be given at application for Home Equity loans, so we do not accept HE apps over the internet.

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