Compliance FAQ's
Does the Online Loan Application comply with ADA requirements?
Requirement: ADA Compliance
Answer
The following ADA criterion are met: TBD
Does the Online Loan Application comply with COPPA regulations, imposing certain requirements for users under the age of 13 and their data?
Requirement:COPPA Compliance
COPPA imposes certain requirements on operators of websites or online services directed to children under 13 years of age, and on operators of other websites or online service that have actual knowledge that they are collecting personal information online from a child under 13 years of age.
Answer
Online Application is intended to be used on customer's banking websites. COPPA only applies if the website directed to children and/or knowingly collect or maintain personal information from children under the age of 13 online. We do not intend children under the age of 13 as the target audience for this service.
Does the Online Loan Application comply with E E-SIGN ACT, providing the option or right for the borrower(s)to receive any or all disclosures in paper form?
Requirement:E-SIGN ACT/ Paper copy
COPPA imposes certain requirements on operators of websites or online services directed to children under 13 years of age, and on operators of other websites or online service that have actual knowledge that they are collecting personal information online from a child under 13 years of age.
Answer
A copy of these provisions will be available for borrowers to view and/or print for their records, whenever they log in again by navigating to the Loan Request screen and scrolling to the bottom of the screen. If they have any questions about any of these provisions before they agree to become legally bound by them, and/or need assistance printing them for their records, they can use any of the Contact Us options to ask us these questions before they decide to proceed and use the online loan application platform to share their information.
What provisions does a borrower(s)/co-borrower(s) bound to when they select 'I consent to electronic communications'?
Requirement: E- SIGN ACT/ Consent Scope - whether the consent applies only to a particular transaction or to categories that may be provided during the parties’ relationship.
Answer
When a borrower(s)/co-borrower(s) selects and proceeds with “I consent to electronic communication, ” they are bound to all the mentioned provisions for that specific credit inquiry.
Does the online Loan Application provide the option to revoke or withdraw consent for primary and/or co borrowers?
Requirement:E-SIGN ACT / Revoke Consent - The right to withdraw consent to have records provided electronically, including any conditions, consequences, or fees associated with doing so. The credit union must describe the procedures for withdrawing consent and for updating information needed to contact the consumer electronically; E- SIGN ACT/ Consent Scope - whether the consent applies only to a particular transaction or to categories that may be provided during the parties’ relationship.
Answer
Online Loan Application requires primary borrowers as well as invited co-borrowers to first consent before proceeding further and then allows them to withdraw their consent at any time. We invite lenders to review the consent and consent revocation language available within the OLA product to help explain who we meet this compliance requirement.
Does the Online Loan Application provide borrowers the hardware and software requirements needed to access and retain the electronic information pertaining to the specific credit inquiry?
Requirement:E-SIGN ACT/Hardware and Software Requirements The E-Sign Act requires that the hardware and software requirements for access to and retention of the electronic information be included within electronic consent.
Answer
Hardware and software requirements are listed in Minimum Systems requirements under Electronic Communication section of the Getting to Know You page.
Does the Online Loan Application have any conditions, consequences or associated fees when withdrawing consent by any party (Borrower(s) or Co-borrower(s)?
Requirement:E-SIGN ACT/Fees - The right to withdraw consent to have records provided electronically, including any conditions, consequences, or fees associated with doing so.
Answer
With Online Loan Application, there are no charges/fees, conditions, or consequences for consenting, revoking, or reviewing a copy of the language they consented to. The product supports these workflows through a self-service model available to the prospective borrower(s) so they can perform these actions on their own.
Does the Online Loan Application provide an option for borrower(s) to enter other sources of income like alimony, child support, or separate maintenance if they want it to be considered in determining the applicants’ credit worthiness?
Requirement:Reg B / Alimony and Child Support discloses that income derived from alimony, child support, or separate maintenance payment need not be revealed if the applicant does not want the creditor to consider the information in determining the applicant’s creditworthiness.
Answer
The Online Loan application does not affirmatively ask for these types of income types; however, borrowers have the option to enter these income types as “Other” in the Employment and income section.
Does the Online Loan Application provide an option for lenders to display logos to satisfy the requirements for Equal housing?
Requirement:Equal housing lender logo disclosure The institution may satisfy the notice requirement by including in the advertisement a copy of the Equal Housing Lender logotype along with the legend "Equal Housing Lender" or "Equal Housing Opportunity."
Answer
Online Loan Application supports logos on each page which can be used by lenders to display the relevant logos to satisfy the requirements for Equal Housing.
Does the Online Loan Application provide an option for lenders to link their annual privacy notice?
Requirement:PRIVACY Notice (REGULATION P) 12 CFR 1016.9 (b) requires an annual privacy notice to be continuously posted on the financial institution’s website.
Answer
Online Loan Application supports the use of a customer-provided privacy policy. The privacy policy is visible to prospective borrowers by clicking on the privacy link included in the Online Loan Application footer available on each page.
Does the Online Loan Application provide an option for lenders to link their annual privacy notice?
Requirement:TRUTH IN LENDING (REG Z) OPEN-END
Answer
Online Loan Applications does not display pricing or promotional information around specific loan offerings. Borrowers should ensure that lenders in this case Banks/Credit Unions or any other financial institute that use Online Loan Application provides accurate promotional information related to these loans.