Credit Score Disclosure and Internet Applications

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Question:

We are thinking about allowing customer to complete a loan application on the Internet and submit it back to the bank via Internet. Must we provide the appropriate disclosures electronically through the Internet? If so what about the new federal consumer credit score disclosure? We will have to run credit before we can get that to the applicant.

Answer:

All applicable disclosures required at the time of applicaiton would have to be given electronically, i.e. ARM Disclosure, HELOC Plan disclosure.

The credit score disclosure can be sent within a reasonable time after obtaining the credit report.

If it's available you may want to purchase a copy of the CD version of Richard Insley's recent webinar on the Esign rules. The webnar's title is:

Tree-free Delivery: How to save big bucks without violating ESIGN. You can find it HERE in the Banker Store.

First published on BankersOnline.com 5/23/05