Answer:
The rules aren't much different than taking a written application. Reg B requirements still need to be met. The difficulty is in getting those taking the application to make sure to read all of the required disclosure language before asking certain application questions. For example, before asking the applicant about income, the application taker needs to read the disclosure telling the applicant that they are not required to include income from alimony, child support or separate maintenance if they don't want that considered in evaluating the credit. As another example, you are required to read the language to the applicant about request for government monitoring information about race and sex on covered loans, telling them that it is not required that they provide that information. Make sure you've got solid scripts for the application takers to use and insist that they follow those scripts to the letter. Document your training on this point in detail. Cover this point often. Have the message reinforced in staff meetings periodically. If you record conversations, consider testing to ensure application takers are following the scripts.
First published on BankersOnline.com 7/21/08
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