Electronic loan processing question

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Question:

Our consumer loans are completed electronically and therefore we no longer print a loan application. Are there any compliance implications if it's not evident by viewing the on-line application, that the financial questions were asked of the borrower(s)?

Answer:

If these are not loans you are selling to investors, such as mortgages which require a FNMA 1003 application, than the application is whatever you require. Certainly you must have enough information to make safe and sound underwriting decisions. Your data must be retained and recoverable for a specified period of time and some BSA requirements will apply to the data content. So long as you have all this, it doesn't matter if you have it on paper, imaged or stored in bits and bytes.

First published on BankersOnline.com 5/23/05