"At the time of application…"

This can depend on the regulation. In the traditional consumer and real estate loan, it means when you receive acompleted application. You have some control over this based on your policy, practices and what is in the requirements. For real estate, as an example, the property should be identified. Without that you could consider it a prequalification.

The new insurance disclosure rules taking effect October 1 may be looked at differently since disclosures are triggered differently and are dependent on the offer of insurance. This is new to all of us.

Internet applications will fall under the same rules above.

First published on BankersOnline.com 10/1/01