Today when there is excess during the analysis process we send a check to the borrower. However we are looking at possibly changing this and if they have accounts with us (do joint loan so joint checking or savings account matter) can we credit the account instead?

We would change the working on the analysis statement from "we are sending you a check" to "if you have an account at ABC Banks, we will credit your account, if not we will send you a check."

Is this acceptable? Or do we need to have the consumer consent/tell us that we can credit their account?

Thanks.

I suppose you could with consent, but it adds a whole layer of maintenance issues, like making sure the names on the loan and deposit account match and the deposit account has not been closed, etc. Not sure all of that outweighs the costs of just cutting and mailing a check without intervention.