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Mortgage/ARMs on the Web

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Question: 
We want to make mortgage loan applications available on our internet banking website. What are some of the issues we need to prepare for?
Answer: 

The good news is that with the regulatory changes that took affect in 2007-2008, you can get the information you need for a mortgage 1003 application without having to go through the E-SIGN compliance steps first. You can collect the monitoring information, a designated title, marital status, provide the alimony notice and provide the appraisal notice, etc. without making E-SIGN disclosures or going through demonstrable consent.

One of the sticking points many banks have problems with is disclosure timing. Remember that if you provide an application for an ARM loan, when the application is given you must also disclose your programs and provide the CHARM booklet. The timing for e-compliance remains the same. Many banks want to snail mail those when they receive the application. You must establish a process so that they are delivered online when the application is taken.

First published on BankersOnline.com 4/06/09

First published on 04/06/2009

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