The LO must go over the form with the customer line by line. This form is serious business for each lender as it involves Fair Lending (Reg B) and ECOA and provides Safe Harbor for the lender.
Ask title if they understand any of that. When they say No, tell them you don't either and only the LO knows the procedures for completing it, be by phone, video, or in person. It's the LO's responsibility as part of the application process.
It's the LO's responsibility to complete this even if the customer refuses based on factors you're not informed of.
I'll post a link to a training webinar the title company can view so they will address this with the lender tomorrow when I'm on my computer.
Or, you can do it. Would also be nice if you say "I'll just check with the CFPB and see if it's okay if I do this. Is that okay with you?". Watch them pull back. |
