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Online Loan Inquiry

Answered by: 
Kathleen Blanchard | CRCM
Richard Insley | Guru Emeritus

Question: 
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?
Answer: 

Answer by Richard Insley:Although I think you are obligated to e-deliver all of the applicable time-of-application disclosures prior to initiating the online pre-application form, submitting it should not constitute an application and start the Reg. B clock ticking.

Answer: 

Answer by Kathleen Blanchard:You will need to define within your lending policy when you have a completed application and therefore the start of the regulatory clock: upon face to face meeting, completion of application, and pulling a credit report.

First published on BankersOnline.com 3/12/07

First published on 03/12/2007

Filed under: 
Lending
Technology
Filed under lending as: 
Credit Report
Disclosures
Filed under technology as: 
Credit Report
Disclosures
IT
Lending

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