ECOA/Reg B has certain time frames in which we are required to notify applicants of our decision. What I am unclear about is how ECOA defines a completed application. Is it one in which all requested conditions have been received as opposed to receipt of a completed form 1003? Is the period for making a decision on a loan based upon the date the borrower applied or based upon the date all conditions were received for review? The Reg B Notice of Incompleteness references the inability to make a credit decision. Does Reg B require receipt of all required conditions before a credit approval can be made?
We offer business credit cards through a third party vendor. The bank currently approves the applications and handles disputes. We are now going with a company that approves the applications and handles all disputes. This company bought all the consumer cards, but did not purchase the business ones. We want to send a letter to the business customers and let them know we are no longer offering business credit cards and within 60 days the cards will no longer be active. Are we in violation of Reg E or Z by doing this?
We want to make mortgage loan applications available on our internet banking website. What are some of the issues we need to prepare for?
Does Reg D apply differently to MMAs than to personal savings accounts? I was told by a senior banker that personal savings accounts were not able to write or order checks. I know that we are able to order MMA checks, so I questioned her. She then stated that personal savings accounts are subject to different applications of Reg D. She stated that this was because MMAs have higher balance requirements so they are given the option of drafting checks. Is she correct?
Our mortgage credit applications contain language that allows the bank to pull a credit report. Often that application is received by phone. Is a signature required to pull the credit report and is so, what regulation contains those rules?
What is the retention schedule for denied loans?
I cannot find the record retention requirement for ATM/Debit card applications in my state's (Connecticut) retention schedule or Reg E. How long do I have to keep ATM/Debit card applications?
I want to verify a procedure on collection of government monitoring information on residential real estate applications. If an application is a telephone application at what point are you required to have the government monitoring data collected either through the customer completing or through visual observation? We have an associate questioning whether the data has to be collected at all on a telephone application. We have been collecting it on the final application signed at closing on telephone applications. What is correct?
We have a loan with two borrowers, a mother and daughter applying for a loan jointly. One of our lenders asked them to complete separate applications. Is this a violation of Reg B? Should all loan applications with two borrowers be listed on the same application unless otherwise requested by the borrowers?
What compliance issues do we need to think about when taking a loan application over the phone? Currently, we do not practice taking them and I am trying to figure out why we don't. Any input or specific resources would be great.