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Electronic Applications

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Question: 
We receive applications for our home equity lines of credit through our web site. Is it OK to mail the brochure and disclosure after receipt of the completed application?
Answer: 

Section 1026.40(b) states that the brochure and disclosure must be provided at the time the application is provided to the consumer. Generally when the consumer indicates that the application is for a home equity line, the brochure and disclosure should be provided before the application appears on the screen. Comment .40(b) – 2. states, “The disclosures and a brochure need not be provided when a general purpose application is given to a consumer unless the application indicates that is can be used to apply for a home equity plan.

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Learn more about Jack Holzknecht’s Regulation Z Rules for Home Equity Lines of Credit webinar.

First published on 08/22/2021

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