When we receive loan applications online and they are not fully completed…like in this case we have one where an app was done online on our website and they did not select for a credit report to be ran and stopped the app from continuing…what do we do with these apps in this case? It is a “not yet completed” app that is just sitting there.

Would this application be considered an "expressly withdrawn" application or a "not completed" application? Would we need to send the applicant a request for more information or treat it as an "expressly withdrawn" application? Also do we need to keep copies of these applications for 25 months?

You may call the online form an "application form", but it's nothing but doodles until the consumer clicks the final "Submit" button. It's the same thing as a partially completed paper form that never makes it off the kitchen table.

So if it hasn't been completed or technically submitted, does that mean that we don't have to do anything with it? So we shouldn't worry about sending a notice of incomplete application?

Reg. B requires no notices until there has been an "application"...defined as: "an oral or written request for an extension of credit that is made in accordance with procedures used by a creditor for the type of credit requested."

Surely your procedures for paper applications don't call it an "application" when a customer takes a blank form home to fill out. It only becomes an "application" when the applicant signs it and mails or hand delivers it to your bank. Likewise, your procedures for online forms don't call an e-form an "application" until the applicant clicks the button or link that submits the content of the form for consideration and a credit decision.

If the consumer has not submitted anything, then you don't have an application. Scraps of information you might have pending in a data system don't mean anything unless the consumer submits them for consideration.