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#1359229 - 03/17/10 06:14 PM No Action Taken
Linkpars Offline
100 Club
Joined: Jan 2007
Posts: 179
Kentucky
Does anyone know if there is a time frame to hold an application? For example, we have a customer that applied for a MTG and he was approved, but he has since went to work out of town and has not made it back to complete the paper work. My questions is, is there somewhere that states what kind of time frame we can hold the loan, or is that the bank's call.

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Lending Compliance
#1359234 - 03/17/10 06:20 PM Re: No Action Taken Linkpars
Lissa P. Offline
Gold Star
Joined: Oct 2003
Posts: 474
Texas, USA
It's my understanding that you can hold the application as "pending" until your bank feels the financial data would not be current. We try not to allow applications to stay in pending more than 90 days.

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#1359255 - 03/17/10 06:39 PM Re: No Action Taken Lissa P.
Linkpars Offline
100 Club
Joined: Jan 2007
Posts: 179
Kentucky
Well I found this in my process of looking, "If an application is received and approved by your bank but you do not hear from the applicant within 30 days, the application can be considered withdrawn. Your bank does not have to send further notification to the applicant."

This is what we are going to go by for now. Thanks for the input!

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#1359261 - 03/17/10 06:48 PM Re: No Action Taken Linkpars
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,844
Bloomington, IN
That is a Reg B allowance. Since your loan request is subject to HMDA reporting you have to report it as approved but not accepted, you cannot report it as a withdrawn application.

As Lisa said the time you hold an approved application is your call. I would agree that 30 to 45 days would be a sufficient time in most cases, of course if a date was specified in a commitment or pre-approval/qualification letter you have to abide by that date.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1359266 - 03/17/10 06:54 PM Re: No Action Taken Dan Persfull
Linkpars Offline
100 Club
Joined: Jan 2007
Posts: 179
Kentucky
Dan, yes I agree. I would list this on HMDA and choose that it was approved but not excepted. We have chosen to stick to 30 after, that way no loans slip through the cracks and don't get listed on HMDA.

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