What can a mortgage loan originator (MLO) do if a borrower's file requires a verification of deposit (VOD) and the borrower currently has no money?

In a scenario where a borrower's file needs a verification of deposit (VOD) and the borrower has no funds at that moment, the most appropriate action is for the mortgage loan originator to request that the verification takes place after the borrower has deposited funds. This means that the MLO can allow a certain period for the borrower to secure the necessary funds and then provide the appropriate documentation to verify those funds.

This approach ensures that the necessary due diligence is maintained while also providing the borrower with an opportunity to fulfill the requirements for lending. It reflects an understanding that circumstances can change and allows for the verification process to be more flexible and considerate of the borrower's situation.

By contrast, options that suggest the MLO should lend money directly or encourage the borrower to take out a payday advance are not standard practices and could lead to potential compliance issues or ethical concerns. Rejecting the loan application outright without exploring the option of waiting for the funds is also unnecessarily harsh and does not provide the borrower with a fair opportunity to secure funding. Therefore, waiting for the funds to be deposited before conducting the VOD is the most sensible and compliant choice.