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#1689254 - 04/16/12 09:43 PM "consumer loan applications"
Patricia Offline
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Joined: Mar 2011
Posts: 327
Kansas
I know that it is not required to obtain an application for a consumer loan. However, management has stated that a previous application can be used if it is dated within one year. Can someone give me some advice as to why you would not want to do this?
Thanks.

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#1689312 - 04/17/12 12:52 PM Re: "consumer loan applications" Patricia
manimal Offline
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manimal
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Posts: 2,207
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My first thought would be to take a look at Reg. B, especially the timing requirements and documenting intent to apply jointly. But I am interested to hear what others have to say.
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#1689320 - 04/17/12 01:20 PM Re: "consumer loan applications" Patricia
raitchjay Offline
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Joined: Oct 2009
Posts: 8,594
OK
I too am interested in what others have to say, but my first thought is that an old application has nothing at all to do with the current application for credit.
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#1689325 - 04/17/12 01:30 PM Re: "consumer loan applications" Patricia
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
At a previous bank, we "accepted" old applications within 15 months solely if that old application was being used as the financial statement. BUT the loan officer still had to get it re-certified by the customer as to it's continued validity (initials and date) and had to document the new request. Most times, the officer would complete a new application (request info, name and signature) and write see attached on the financials section, then staple a copy of the old application to the new one.

While written applications are not required for consumer loans (I'm assuming we are talking about non-RE loans here), you still want to document the request, especially if you sell credit life or other insurance products. We use the application to document date received for the insurance disclosure, joint intent, and HMDA data if the loan is for HI (we report non-RE HI loans).
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#1689331 - 04/17/12 01:41 PM Re: "consumer loan applications" Patricia
Rocky P Offline
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Joined: Jun 2003
Posts: 7,258
Florida
IMHO, I may be getting confused with what you're trying to say - the application as a piece of paper, or a request for credit.

As a piece of paper, it should be immaterial (except for the date) if the information is the same, and the bank is trying not to inconvenience the customer. It might be best if a copy of the original were used, and the customer(s) initial the intent to apply jointly, update the employment and liabilities section and re-date the application. If it were electronic, it would be easier.

As a request for credit, there should be no confusion between old and new applications. What happened 6 months ago is history. This is a new request, along with all accompanying timeframes and disclosures.
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