We are adding some enhancements to our online application process. This would be for individuals that would auto approve only. Better qualified borrowers would go to an separate screen, which would have the following information:

1) Suggested Loan Amount
2) Estimated Payment
3) Estimated Term
4) Estimated APR

I am a one person shop, so I appreciate any advice on what things to consider as I develop the disclosures.

Thank you,

Jake

I am not really following. You mean other than the advertising rules?

Yes. We'll stick our normal advertising disclosure on the screen, but I wanted to make sure that I wasn't failing to consider anything obvious.

Thank you!

Is the bank limiting geographies to their assessment area? / and is that noted and filtered before the application?

I guess I am still not sure what that information represents. Is that amount for which the customer is pre-approved? What are those figures based on - is that what they applied for? I guess I do not understand its meaning to the consumer. Can they then click and get the loan? What are the next steps? Are these secured or unsecured loans? What happens to the applicants that do not make it through the process to this screen? There are way too many questions, so it is difficult to begin formulating any response without knowing the whole story.

These borrowers would be applying for either an unsecured term loan. We are an FCU, so anyone not eligible for membership should be screened out earlier in the process.

Early in the application process, they will be answering the question “How much would you like to borrow?” where their options are:
• Less than $2500
• $2500 or greater

Before they can enter a requested amount, they will see this screen if:
1) They responded $2500 or greater
2) Their credit score & ratios can qualify for a loan equal to or greater than $2500

If they wouldn’t qualify for a loan of $2500 or more or they selected Less than $2500, this screen is not visible and it jumps directly to a screen where they can manually enter their request.

• The intent of the screen is to give them an estimated amount, not to necessarily guarantee approval or steer them towards requesting more (or less) than they would like
• After seeing this screen, they have the ability to customize the requested amount and term

So - you prequalify them before they can request an amount and then you only provide some applicants this information - talk about treating applicants differently.

You use the term "auto approve" which also means auto-deny. Are you getting info in advance so that an adverse action can be sent to those being denied? You're factoring in credit scores and other info and while you also said this is a screening process, I would be cautious if it is more of a decisioning process. I'm not reading enough to know what this is, but I'm cautious. There are ECOAS and fair lending issues in this.

Based on some of the comments raised, management has put a hold on this project. Thank you for the feedback. Much appreciated.

JB