Loan Applications Received Via Email

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Question:

If we receive a closed end consumer residential ARM loan application via email, when are we supposed to send the CHARM booklet and ARM early disclosures: the day we gave the application to the customer to be filled out or the day we received the application from the customer?

Answer:

ARM disclosures are supposed to be provided when the application is given to the customer. If you did not know the customer was requesting an ARM, you should mail the ARM disclosures within 3 business days.Refer to section 226.19(b) and footnote 45b of Regulation Z.

First published on BankersOnline.com 1/24/11