Required Method of E-Early Disclosures

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Question:

In providing the HELOC early disclosures with an Internet application, is it acceptable to provide the disclosures via a link (before the applicant gets to the application) which link the applicant can bypass?

Answer:

Bypassable links do not satisfy the Fed's optional e-delivery regulations, so by choosing this approach, you are walking away from a safe harbor. It's not difficult to add one more page to the flow of the links (click here to apply...but first - a word from your government...now click here for our application.) You don't need any kind of receipt or acknowledgement for the booklet or preap and you can put the outbound link at the top of the disclosure page. Why is one more click such a major inconvenience?

First published on BankersOnline.com 7/24/06