We do not complete an application for a renewal. We first thought about using the maturity date for the application date. But some of our loan officers do process their renewals before the maturity date (they receive a report of renewals due in 30 days). We are concerned about the timing of the appraisal notice. What are you using as your date for loan renewals?

Since you don't have a written application at renewal, I would presume there is some verbal contact between the lender and the customer, in which the customer requests a renewal of the loan. In my opinion, that is the application date the starts the timing on your notice.

Loan officer receives report of impending maturities. Loan Officer starts contacting borrowers to determine how to proceed. A borrower says he or she will need a renewal. Bingo! That's your trigger date.

Thank you.

We have a closing instructions form where the loan officer is required to note the date of the application and the date the disclosure was given.