Answer by David Dickinson:Any disclosures triggered by the type of loan applied for need to be provided at the website. For instance, if you are allowing applicants to apply for an ARM, you must provide the Program Disclosure and CHARMs booklet at that time. If they are applying for a HELOC, you'll need to provide the HELOC Booklet and Program Disclosure.
Answer by Richard Insley:As David explains, product-specific disclosures are controlled by the familiar regs (B, Z, RESPA, flood, etc.) Pay attention to format and timing requirements, anything that must be "in writing" and delivered immediately must be e-delivered and that usually triggers ESIGN. ESIGN has its own set of how-our-e-delivery-system-works disclosures which must be given as the first step in the demonstrable consent process.
First published on BankersOnline.com 12/14/09