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#1465599 - 11/08/10 09:11 PM Reg B Question
Law78 Offline
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Joined: Oct 2010
Posts: 38
I am looking for opinions:

Loan is run thru AU - result is approved ineligble.

Underwriting has not denied or provided a counter offer on the loan so in order to satisfy the 30 day clock the loan is denied for incomplete application. Comments?

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#1465613 - 11/08/10 09:29 PM Re: Reg B Question Law78
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
I assume the Automated Underwriting denied it since it's "approved ineligible". Why was it denied? Doesn't sound like incomplete is the correct reason for denial.
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#1465630 - 11/08/10 09:50 PM Re: Reg B Question Dan Persfull
Law78 Offline
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Joined: Oct 2010
Posts: 38
It isnt a correct denial reason- the loan was never reveiwed in underwriting or counter offered. The loans would contain various reasons for the approved inelgible results.
Lets say for example files are behind in underwriting and in managing the pipeline it is discovered a group of loans are within days of the 30 day expiration. If an underwriting decison has not been made the loan would be denied for incomplete application in order to avoid a REG B violation.

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#1465634 - 11/08/10 09:55 PM Re: Reg B Question Law78
Dan Persfull Offline
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Dan Persfull
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Posts: 46,844
Bloomington, IN
Sorry, you can't use incomplete application simply because your application process is behind and it doesn't allow you to review the application within the required time.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1465639 - 11/08/10 10:01 PM Re: Reg B Question Dan Persfull
Law78 Offline
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Joined: Oct 2010
Posts: 38
That is my opinion too - I am just trying to determine all the implications and wondered if anyone else was of the opinion it was justified - and if so why. Thank you

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#1465646 - 11/08/10 10:03 PM Re: Reg B Question Law78
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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I agree it is not justified. Can someone review the files and issue a notice of incomplete application with a list of additional information needed to make a decision?
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#1465662 - 11/08/10 10:30 PM Re: Reg B Question Kathleen O. Blanchard
Law78 Offline
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Joined: Oct 2010
Posts: 38
I suppose the response would be if we could reveiw the file we would deny it accordingly.
My thoughts-when we have an application without the intent to proceed we may be able to deny for incomplete application but once the intent is received it must go thru the appropriate underwriting channels and decisioned accordingly.

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#1467289 - 11/12/10 07:18 PM Re: Reg B Question Law78
NotALawyer Offline
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NotALawyer
Joined: Nov 2001
Posts: 455
Help us understand what you mean by "if we could review the file we would deny it accordingly". Were these files manually pulled after a cursory review and a "no" decision so that they wouldn't clog the production line? If you have a decline reason, you can send a decline notice with instructions to contact you for the specific reasons for the denial.

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