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#1396477 - 05/26/10 05:39 PM Reg B - Adverse Action Notice
hmdabecca Offline
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Joined: Mar 2010
Posts: 15
I have a denial we completed that is stating, Income insufficient for amount of credit requested and Excessive obligation in relation to income as reasons for denial. It has been my understanding that these 2 should not be used together but instead as an either or situation. Does anyone have any comments to this? All help would be appreciated!!! Thanks

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Audit
#1396551 - 05/26/10 06:47 PM Re: Reg B - Adverse Action Notice hmdabecca
Book Nerd Offline
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Book Nerd
Joined: Jun 2007
Posts: 447
New England
There is an adverse action guideline in the banker's tool section that you might like.

My advice is to use excessive obligations when the debt to income is higher than you would typically allow prior to considering the new loan amount.

We use income insufficient when the debt to income ratios are within guidelines, but when you consider the new loan, the debt to income ratios go higher than we would typically allow.
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Sometimes the questions are complicated and the answers are simple. - Dr. Suess

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#1396642 - 05/26/10 07:49 PM Re: Reg B - Adverse Action Notice Book Nerd
hmdabecca Offline
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Joined: Mar 2010
Posts: 15
i have the guide to adverse action but i was needing the regulatory source as to where this could be found as an either or situation.

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#1396870 - 05/27/10 12:47 AM Re: Reg B - Adverse Action Notice hmdabecca
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
There is no regulatory guidance.
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