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Using 1003 for HELOC Applications

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Question: 
We are currently using a 1003 for our HELOC applications. Our consumer lending team wants to discontinue the 1003 altogether for HELOCs. The loan officer would obtain much of the same information verbally and input the information directly into our loan origination system. The loan officer would verbally ask for GMI and obtain joint intent (when applicable.) Disclosure scripts would be provided for the loan officer, who would click a radio button indicating that the script had been read. My research indicates that this method is permissible for both GMI and joint intent requirements. That said, is there any other reason why we would need a HELOC application form? Our consumer team is telling us that we're the only bank that uses a 1003 for HELOCs, and they're questioning the reason we need to continue the practice.
Answer: 

Unless you are selling mortgage loans to investors, there is no requirement to use a 1003 on any loan.

First published on 03/25/2018

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