Do we need to track application dates for renewals for existing loans (to comply with Reg B timing requirements)?

I say yes, but I have commercial lenders that argue with me syaing that they never really took an application for the renewal....they did a loan a year ago, it comes up for maturity, they call the borrower and get updated financials, do another CAR, get the renewal approved, etc. There is no "application" they collect for a renewal.

My issue with this is that we cannot accurately track it for Reg B compliance to ensure we are rendering decisions in 30 days.

Does anyone else have trouble with this and if so, how have you handeled it?

An application does not have to be on a formal written application form. Once they contact the customer about renewing the loan and getting their financials and the borrower's agreement to continue with the renewal process they have just created an application request for the renewal.

If they don't budge continue citing it and when the examiners find it in your compliance reports to senior management and the board they will soon change their tune.

This says to me that the bank's procedures and training on Reg B need enhancement. For example, the Reg B policy/procedure at a large commercial bank where I once worked stated:

"For existing customers, when all required information is already on file, a phone call or meeting to make the request can be considered a complete application."

How have you been documenting the date of the application - a lender memo to the file?

Banks do this in a variety of ways:

>memo to file (perhaps an online file)
>note in online CRM system from which reports can be pulled
>date of new request on a deal pipeline tracking report

Edited:

Other dates banks use for commercial application dates:

>date of loan approval memo
>date financials sent for spreading
>date of acceptance of "term sheet for discussion purposes" with payment of fee - bank will go forward with due diligence etc at that point in order to reach a decision