Hello, I just have a basic question about completing consumer applications. We recently went through an internal audit and one of our recommendations was to properly document how loan applications were completed, whether they are taken face to face, or by phone etc. Does this need to be documented only when you collect the government monitoring information or should this be collected on all apps?
The internal audit was of Reg. B, but they did not reference a specific section. We already document how applications are taken for HMDA loans ; however I am unsure if they mean that we are not consistently documenting this for HMDA loan applications or if we should be doing this for all loan applications.
Reg B applies to all loans. I’ve looked through the reg and I can’t find anywhere that specifically says that you have to document how the applicant applied for the loan. That being said I did find where it talked about certain things you could do to stay in compliance if the application was taken over the phone.
By denoting how the application was taken this would give your Auditors & Examiners the information they need to decide on what they should be looking for.
I would say they want you to have this for all of your loans. In our loan processing software it is as simple as clicking a box to get this done.