When it comes to reporting Section 1071 data, a financial institution must indicate whether a covered application was submitted in person, by phone, online or by mail. While these options may seem pretty straightforward, you will undoubtedly run into situations where someone may have initially applied by phone but later dropped off some financial paperwork in person, or some other similar circumstances. Remember, the “method” is not based on when you have a completed application, but rather how the initial request was made. So, in this scenario, the method would be “by phone” (if the applicant initially called in to request credit). The only way to get the application method reported accurately is to understand “when” you have a covered application and it will require some documentation.
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