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On-line Application and Pre-Qualifications

My institution is beginning an on-line mortgage application process and pre-qualification program. I have some questions with what follow up procedures should be. #1 Individual sees our site and enters a couple of pieces of information, but does not have a completed application. What should be our follow up? #2 The individual completes the application on-line but does not follow up within the 30 days with other required information. Is this an incomplete application? Also, on a prequalification, the individual is notified of being qualified and receives letter stating this online, but does nothing in the allotted time period. Are we required any documentation be sent to applicant? I know this is a lot of questions, but there are so many variables. We are trying to set up our procedures. Any other information in regards to on-line application and pre-qualifications would greatly be appreciated.

by Richard Insley:

re #1: Until an online applicant hits a "submit" button (or a similar triggering device), s/he has done nothing more than a traditional applicant who starts to fill out a paper application form and leaves it on the kitchen table. You don't consider the latter to be an "application." Based on identical logic, neither is the former.


by David Dickinson:

Re #2: You have a request for credit (an application). It may be incomplete, but you need to follow up with the applicants per §1002.9(c)(1).

Re: prequalifications: If you have approved the prequalification and the applicant stops providing information, technically, you do not need to send a notice of incompleteness (NOI). Refer to the Commentary to §1002.9(c)(1):
1. Exception for preapprovals. The requirement to provide a notice of incompleteness does not apply to preapprovals that constitute applications under §1002.2(f).

However, most institutions do provide a NOI to prompt the applicant and because this is a gray area.

First published on 01/13/2019

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