Is a electronic signature under E-SIGN sufficient to justify our pulling a credit bureau check on an applicant?
We are looking at an e-banking product that allows accounts to be opened and funded without the customer ever coming into a branch. How do we satisfy the CIP requirements for account opening if we never meet them face to face?
Our lending department wants to set up an online process where customers can submit a loan inquiry from our Web Site that would include almost all of the information that is on a normal face-to-face application. The information gathered would only be used, and a credit report run, once a face-to-face meeting has occurred. They are looking for a way to speed up the application process for the customer. I would like to know if this is possible or would it be considered that we have really received an application when we receive the information from the Web site?
- Due to new technology that catches fraud on the first or second purchase, rather than the fifth or sixth, credit card estimated losses due to fraud are at an all time low of 5¢ of every $100 c
We are thinking about allowing customer to complete a loan application on the Internet and submit it back to the bank via Internet. Must we provide the appropriate disclosures electronically through the Internet? If so what about the new federal consumer credit score disclosure? We will have to run credit before we can get that to the applicant.
We have a POS and LOS system for our mortgage applications. My question is, if a Member starts an application on the website, runs a credit report but closes out of the system before they have finished the input and the Desktop Underwriter doesn't make a credit decision, does this loan have to be submitted to HMDA? It can't be pushed to our LOS system without the DU response and is considered an "unsubmitted" by our company. Please advise.
We are a small three branch bank. Our CEO is pressuring the staff to open new checking/savings accounts online at our website. I have been to numerous banking seminars, and from what I understand, banks that currently are opening up new accounts on their websites are suffering substantial losses. What can we do to prevent this from happening at our institution in the event we decide to open new accounts on the Web? And can we restrict the opening of new accounts to residents of our state only?
Michele Petry, Ph.D., BankersOnline.com