Answer:
Yes. Reg B defines "application" very broadly to include situations such as this. The reason the definition of "application" is so broad, is to impose the law's non-discrimination requirements on any party, including a loan broker, who has the ability to influence the outcome of a credit decision.
Reg B does permit lenders to establish procedures for taking applications. But procedures, regardless of how they are defined in policy, are measured by what the lender actually does. So taking and considering such an information practice from Broker A would establish the practice and looking at a package from Broker B would therefore be an application.
First published on BankersOnline.com 3/13/06
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