I've seen several opinions on this, and I'm hoping you can clarify it for me. It is my understanding based on reading Official Staff Commentary to REG B and REG C , that loan apps taken over the Internet are treated as mail applications. That is also the answer I got in response when posing the question on BOL. However, I've now been told that the usual exceptions for delayed disclosure do not apply to Internet applications. I'm confused, any wisdom you can provide would be appreciated.
Can you take applications for loans over the phone and pull credit? If the customer never comes in and the request is denied, what do you do with the application that has not been signed by the customer that gives you permission to pull credit?
Do we have sufficient authorization to pull a credit report when we take a telephone application?
Reg B and Intent to Apply for Joint Credit Question. Thank you for the wonderful clarification with the article on Reg B Roundup. Our team and attorneys have discussed at length the best way to establish a person's intent to become jointly liable for a credit obligation at the time of application. This regulation change impacts products differently based on the product process but I’m particularly interested in understanding what other lenders are planning to do to satisfy this change when taking applications over the phone or internet. We are checking with other industry contacts. Do you have any more specific guidance on phone applications for consumer finance (Auto, unsecured)?