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#282197 - 11/30/04 08:42 PM Adverse Action Notice on a Verbal App
someone else Offline
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someone else
Joined: Aug 2004
Posts: 3,300
back to my roots
Scenario: Applicant applies for a loan with a loan officer verbally. Gives all relevant data. At the end of the discussion, applicant discloses that he/she has a recent bankruptcy. Loan officer tells the applicant that we cannot do this loan because we do not lend on recent bankruptcies.

Question 1: Should an AAN be sent?

Question 2: What if the first question from the applicant, before any relevant data had been given, was Do you accept bankruptcies? What then? AAN?
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Lending Compliance
#282198 - 11/30/04 08:45 PM Re: Adverse Action Notice on a Verbal App
GreatBlue Offline
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GreatBlue
Joined: Feb 2003
Posts: 2,362
Colorado
1. Yes, absolutely.

2. A little harder. The LO can tell the applicant what your policy is. For example, "We generally do not make loans if the applicant has declared bankruptcy in the last 2 years." If they apply the policy to the applicant's situation, then they cross the line and AAN is required.
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#282199 - 11/30/04 08:47 PM Re: Adverse Action Notice on a Verbal App
someone else Offline
Power Poster
someone else
Joined: Aug 2004
Posts: 3,300
back to my roots
My feelings exactly. Thank you GreatBlue, that was just what I wanted to hear!
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Somewhere, something incredible is waiting to be known. - Carl Sagan

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