Answer:
Sure. No where in any regulation does it require a customer to fill out a loan application. In fact, Reg B makes it very clear that an verbal discussion can very well be an application [refer to Section 202.2(f) and it's commentary]. Reg B does require written applications for some dwelling secured loans, but even then it's not the applicant's requirement - it's the loan officers [refer to Section 202.4(c)].
If something was said that made the loan officer believe that s/he didn't need to "waste" time completing an application or pulling a credit report, that information should be documented and a denial should be sent to the applicant(s). It doesn't make any sense to also pull a credit report or waste time filling out an application form, if the loan officer already knows a loan will not be conducted.
First published on BankersOnline.com 9/5/11
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