Scenario:
We receive a request for a mortgage loan prequal via phone, email, or possibly even the internet.
-No property listed or identified.
-No signed application.
-Credit is pulled but no verification of any other info.
-We issue a general prequal statement saying they appear to be qualified, please contact us when you are ready.
I know that we would be subject to Reg B and FCRA in terms of a possible adverse action notice but if not adverse and we never hear back from the potential borrower is there any further action required, or more importantly, is their any specific requirement to retain the file docs? i.e. the unsigned loan application which is very incomplete and Credit report they reviewed.
Looks like Reg B 202.12 is the applicable law but not sure it would apply here.??
This tends to happen from time to time when the potential borrower either loses interest, goes to another lender, or just goes away.
Thanks!
Last edited by Dallas Fan; 07/14/11 09:00 PM.