I would like to know if other banks are using their loan platform to enter application information. We are implementing a new platform software and it includes an application module. I think it would create consistency to use the module. I am getting some resistance from the Loan personnel. We have already had auditors note that there are incomplete applications in our loan files and some have no applications at all! They of course want to know where it says in the regulations that we have to have a completed application. Any comments or suggestions would be appreciated!

Commentary to 202.13:

2. Principal residence. The requirements of § 202.13 apply only if an application relates to a dwelling that is or will be occupied by the applicant as the principal residence.

2. Written applications. The regulation requires written applications for the types of credit covered by § 202.13. A creditor can satisfy this requirement by recording on paper or by means of computer the information that the applicant provides orally and that the creditor normally considers in a credit decision.


Notice the last part of the sentence "that the creditor normally considers in a credit decision". So if you don't have all the information recorded that you normally use in the credit decisions for that loan type then you have a potential violation.

Dan,

Thank you for the guidance!

An,
Do your people really think it would be OK to have incomplete or non-existent applications? Those evil compliance people want LO's to do their job...so unreasonable.