I am in the midst of a Reg. B Adverse Action review, and while working through a report our underwriting department uses for tracking applications, I found a one that had no Denied/Withdrawn file. The head of our underwriting department informed me that the application was withdrawn, as the applicant decided to stay with their current bank.

When I asked the Lending Officer about it, I was told the file was "on hold"... which to me means the Lender is hanging on to the applicant's info for future sales pitches. Have you run across this with any of your lenders? What do you do? To me, if the applicant truly said "I'm staying with my current bank," the application is Withrdawn. But the Lender seems to think they can keep the file 'open'. Thoughts? Thanks!

How about a little refresher training? The official Bank file has to be dispositioned according to the Regulation B rules and maintained for HMDA reporting and Regulation B retention purposes. What they may want to do with a shadow file (if your bank allows them) is up to the loan officer. There are no excuses here and it appears that the loan officer needs remedial Regulation B training. The internal controls in the underwriting department to ensure that all applications in the pipeline are processed timely also needs review.

And the lender needs to realize that closing out this particular application does not mean that all future contact with this prospect is cut off. The two are unrelated.

Do the above, take the file from them, hit them with the file.

That's what I've done in the past.

Thank you for all the insight (and humor ). Working to improve how we process applications has been a huge part of my efforts ever since I took over the department here. And we still have a ways to go!

You could add a nice Jethro Gibbs slap to the back of the head (for you NCIS watchers). I think the Gibbs slap is a great technique for lots of situations.

I am picturing the Severus Snape smack to the back of the head. Sometimes he uses a book.

::grabs ABA Guide to Regulatory Compliance::

I'm not very familiar with Harry Potter, but it sounds workable to me.