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New loan numbers for customers who reapply
Question: Should we use a new loan number if a customer that withdrew or canceled an application reapplies?
Answer: The short answer is yes. Simple logic tells you this is necessary. How else can you tell those two applications apart? They are different applications and must be recognized as separate applications for most compliance purposes, including HMDA for accurate LAR reporting, Truth in Lending for timely early disclosures, ECOA for processing times and notifications, FCRA to be sure there is a legitimate business purpose for pulling the credit report, RESPA for timely early disclosures, and Flood for timely and accurate determinations. And if someone wants a technical answer, remind them that each loan application reported on the LAR must have a unique identifier.
Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 3, 3/02
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