Skip to content

Requesting Tax Returns at Time of Application

Answered by: 

The December 19, 2011 BankersOnline Weekly Banker Briefing contained an article under the lending section titled, "Requesting Tax Returns at Time of Application." I believe the answer given was incorrect. The BOL Guru stated that you can not "ask for verification documents until after the GFE is delivered and the applicant has indicated they wish to continue." What the regulation actually states is that you cannot require, “as a condition for providing a GFE, that an applicant submit supplemental documentation to verify the information provided on the application.” Is this correct?

You are correct; however, if you request them how does the applicant know you aren't requiring them? Is that clear to the applicant? Would an examiner "buy" it if the loan officer states "I didn't require it. I just told them I needed it"?

Here's an excerpt from our training manual on this topic:

Lenders can ask for "voluntary" verification information.

Voluntary Verification Letter. List what verification documents you need to evaluate a preapproval request. Make it clear that this is voluntary and have the applicant sign a statement attesting to the fact that they are providing this information voluntarily.

First published on 5/28/12

First published on 05/28/2012

Filed under: 
Filed under compliance as: 
Filed under lending as: 

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics