Using One Application For Checking, Savings, Cash Accounts & Loans

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Question:

Management wants to reduce paperwork by creating one application for many bank products. They want to take the application for checking, savings and ready cash accounts and add blanks for HMDA reporting data on the back of the application so it be can used for loan applications as well. The instructions on the back will state the HMDA reporting information is to be completed by creditors only. Are there compliance issues that we should be concerned about?

Answer:

Answer by Lucy Griffin:

While it is possible to design such a form, the ones I have seen tend to look like monsters. They are intimidating to both loan officers and applicants. The biggest challenge if you choose to design a oneforall form is training. This places a heavier burden on your loan officers and CSRs to know the requirements and to be able to explain to customers how they should fill them out.

Answer:

Answer by Jim Bedsole:

I agree with Lucy. Plus you've got an issue with your wording on the back with regard to HMDA data. Regulation C requires that you give the applicant the opportunity to provide the information requested before the lender is obligated to note the information. The lender should only be completing the HMDA data for those cases where the applicant chooses not to provide the information.

First published on BankersOnline.com 3/17/03