Posted By: CloudShape
not face to face but known - 01/27/21 01:54 PM
Not sure if anyone else has run into this last year or not.
We have a loan that I believe was an oral request, either through email or over the telephone. Due to the pandemic, the loan documents were sent either email or snail mail (probably email). When we got the DI form back, there was one checked off that they did not wish to provide. I don't believe the applicants actually came in until closing, but here is the question - the applicant was personally known to the lender. So can the lender fill out the missing information based on personal knowledge?
I am a little torn because the regulation talks about application time and closing. It does not refer to prior knowledge anywhere. So based on a strict reading, I would say we would have to stick with the did not wish to provide since the applicant was not in person until closing and the lender cannot fill in the missing information based on personal knowledge, even though the information might be valuable.
Thoughts?
We have a loan that I believe was an oral request, either through email or over the telephone. Due to the pandemic, the loan documents were sent either email or snail mail (probably email). When we got the DI form back, there was one checked off that they did not wish to provide. I don't believe the applicants actually came in until closing, but here is the question - the applicant was personally known to the lender. So can the lender fill out the missing information based on personal knowledge?
I am a little torn because the regulation talks about application time and closing. It does not refer to prior knowledge anywhere. So based on a strict reading, I would say we would have to stick with the did not wish to provide since the applicant was not in person until closing and the lender cannot fill in the missing information based on personal knowledge, even though the information might be valuable.
Thoughts?