We are trying to figure out how to centralize the distribution of loan disclosures to the back room. For anybody who has already tackled this, how do you deal with the disclosures that have to be provided at application when taken face-to-face?

Did you define application to include timing so that these disclosures are provided with the other initial disclosures?

Disclosures for what types of loans?

The ARM and HELOC Plan disclosures cannot be centralized to your backroom operations if this is what you are asking about. Those disclosures must be provided to the consumer at the time they are provided an application or pay a non-refundable fee, whichever occurs first.

All consumer loans.

We don't do any ARM lending (except at our mortgage center). And we only take applications for HELOCs by phone....thus we can mail the HELOC Disclosure that day.

So if I come in and request a HELOC you're going to tell me to go home and call?

No, we will still accept face-to-face applications. We're just trying to figure out how to deliver the disclosures at a time after the application. I can't figure out a way around the HELOC program disclosure.

No. The Customer Service Rep, from his/her desk, puts the customer on the phone with our specialists in the call center. HELOCs and Home Equity Loans in Texas are quite complicated and any fowl-ups can result in an invalid lien. It was impossible to maintain home equity specialists at every branch, so we centralized the process.

I can't figure out a way around the HELOC program disclosure.


There's no way around the ARM disclosure either.