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#1571608 - 06/29/11 05:58 PM Completed application
Southern gal Offline
Platinum Poster
Joined: Mar 2008
Posts: 504
TN
During an AAN review, 3 applications were not dated & 1 did not have a loan request amount entered on application, aren't these Reg B requirements to be a completed application. I'm needing the exact Reg wording for my report, where is this referenced?

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Lending Compliance
#1571669 - 06/29/11 06:42 PM Re: Completed application Southern gal
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
There's no requirement for applicants to submit anything in writing for the request to meet the definition of an application (verbal applications are still applications).

Application not dated: The loan officer should document the date the application was received. This isn't a requirement of any regulation - just a way to prove you provided disclosures or the AAN in a timely manner. Therefore, you won't find any regulatory reference to support this - either way.

No loan amount:
Again, the loan officer should document what was being requested. If an AAN was completed, that tells me the loan officer knew what was being requested. If there truly was no loan amount, then I would argue you don't have an application. Refer to 202.2(f).

I recommend you check out the webinar I recently conducted for BOL entitled "Applicants and Applications". We go into great detail about what is and is not an application, like the questions you ask. You can find more info here:
http://calendar.bollearningconnect.com/main.php?view=event&eventid=1303414477688
_________________________
David Dickinson
http://www.bankerscompliance.com

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#1571709 - 06/29/11 07:07 PM Re: Completed application David Dickinson
Southern gal Offline
Platinum Poster
Joined: Mar 2008
Posts: 504
TN
Thanks

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