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#1526616 - 03/24/11 06:22 PM Incomplete Application
JW QC Audit Offline
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Joined: Aug 2008
Posts: 50
Scenario:

Application Dated: 6/28/10
In-Process: 7/7/10
NOIA Sent(Notification of incomplete application) 7/14/10
In Underwriting: 01/10/10
application Continuous open , but is closed by incomplete application: 10/20/10

1.From the date of the application 6/28/10 to reach the processing department 7/7/10 , there are 9 days.
2.From Processing Dept.7/7/10 to send the NOIA (Notification of incomplete Application ) 7/14/10, there are 7 days
3.From the date of NOIA was send 7/14/10, to reach the underwriter 10/01/10, there are 77 days
4.For some reason, the application is open until 10/20/10.there are 19 days (According to the notes, the client does not complete the request) (Incomplete Apllication on Processing) From the date of the application to the date of the action Taken (Incomplete Aplication) there are 112 Days.

A. NOIA (Notification of incomplete application) has more than 30 days for the customer complete the request (more than 30 days is right?)

B.There any violation to the period established by ECOA (Reg.B)

C.System indicates -incomplete application date was 7/14/10. But in fact the case was incomplete on 10/20/10. I understand that between the reg. Reg B and C there is a difference in the action taken date? This is correct?, what is the correct action taken date?.

Thanks,

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Audit
#1537849 - 04/20/11 01:36 PM Re: Incomplete Application JW QC Audit
JW QC Audit Offline
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Joined: Aug 2008
Posts: 50
anyone?

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#1537862 - 04/20/11 01:45 PM Re: Incomplete Application JW QC Audit
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
The application reached the underwriter in October. Was the file closed for incompleteness upon expiration of the NOIA (the date provided in the NOIA letter if done correctly)? Was the application reopened when the customer came back later with the needed information (same ap number) or was a new ap started when the customer came back?

OR, was the delay for a reason unrelated to the customer not returning with the requested information?
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
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#1537944 - 04/20/11 03:09 PM Re: Incomplete Application Kathleen O. Blanchard
JW QC Audit Offline
Member
Joined: Aug 2008
Posts: 50
1.Yes the application reached the underwriter in october.
2. Same application
3.Yes, was close for incompleteness after the expiration date, The client did not complete the requested documents.
4. NOIA (Notification of incomplete application) has more than 30 days for the customer complete the request (more than 30 days is right?)

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#1537958 - 04/20/11 03:25 PM Re: Incomplete Application JW QC Audit
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
So, then did the client come back with the needed information and the application was reactivated and sent to underwriting?

That would be okay, and you can use the original application date.

It is fine for a NOIA to provide more than 30 days; it is not the "norm" but not wrong. You put the time frame that you think will be needed...more complex documents, give more time.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1537962 - 04/20/11 03:28 PM Re: Incomplete Application Kathleen O. Blanchard
JW QC Audit Offline
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Joined: Aug 2008
Posts: 50
Thanks,,,,,,

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#1537964 - 04/20/11 03:30 PM Re: Incomplete Application JW QC Audit
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
Some banks start over with a new ap number after closing out an ap, but keeping same ap number and date and moving forward is also allowed. Just be consistent.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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