Anyone see a problem sending the Notice of Incomplete Application along with the initial package, which includes the welcome letter, initial disclosures, intent to proceed, etc.?

Do you never have a completed application prior to sending out earlies? That would be my only concern.

I try to never say never, but once we have a 1003 with the 6 pieces of information required under RESPA, the credit report is pulled and the earlies go out. Our definition of a "complete application" under ECOA includes things that a lot of the time might not be completed on the 1003--for example, the assets portion or the employment portion.

We incorporate the NOI into the communication that accompanies the earlies and the application package.

Great. It seems to make sense to be upfront about it. If the NOIA needs to go out within 30 days (assuming application is incomplete), why not send it out immediately? Glad to hear someone else is doing it too.