Answer:
No. You have used the electronic media in place of the post office to deliver an application. You are not collecting any information with your web site or email app, and by making a generic application available there are no disclosures that must accompany the application, unless you are offering specifically an ARM, as an example. In that case the CHARM booklet and program disclosures would have to accompany the application.
First published on BankersOnline.com 4/21/08