Autopay Requirements

We offer borrowers an interest rate discount on residential loans for EFT/autopay, but in order to do so, we require they provide us a voided check to verify the account information and the name on the check/account. If the borrower indicates that they wish to have EFT, they will receive a discount, but we want to be able to obtain the voided check earlier in the process to finalize the rate instead of obtaining at closing. Are we able to condition for the voided check prior to final approval, in order to receive the rate discount or is that in violation of regulations?

I am not sure what regulation you would violate. The process for receiving the discount just has to be fair and not involve any deceptive practices. If they cancel later and you raise the interest rate, you realize that turns these into ARM loans - correct? And you would need to issue a modified version of an early ARM disclosure and possible provide an advance notice, if you adjust their payment amount.