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#175585 - 04/01/04 04:22 PM HmDA incomplete application
Tillie Offline
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Tillie
Joined: Apr 2003
Posts: 266
When is it appropriate to report a request as denied & use the code for incomplete application vs. reporting a file as closed for incompleteness?
What makes the two actions different from each other?

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#175586 - 04/01/04 04:25 PM Re: HmDA incomplete application
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
Denial - the application was actually denied for being incomplete.

Closed for Incompleteness - you sent them the notice of incompleteness advising them what information was needed and they did not respond.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#175587 - 04/01/04 07:15 PM Re: HmDA incomplete application
Anonymous
Unregistered

I think I'm a little dense today. Can you give an example? It seems that we would rarely, if never, deny on incompleteness of application but rather report as file incomplete. We would probably give the applicant ample opportunity to get us the needed stuff, which would include giving them the Notice, etc.
Does this sound reasonable?

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#175588 - 04/01/04 07:22 PM Re: HMDA incomplete application
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
This all depends on your procedures/policies.

Reg. B gives you 2 options for incomplete applications.

Within 30 days from receipt of the incomplete application you may send an AAN outright denying the application for being incomplete, OR you may send a notice of incompleteness advising the applicant that you need this information by this date or no further action will be taken.

If you outright deny for being incomplete you would report as a denial. If you send the notice of incompleteness and the applicant does not respond then you report as being closed for incompleteness once you actually "closed" the application request.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#175589 - 04/01/04 09:06 PM Re: HMDA incomplete application
hmdagal Online
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hmdagal
Joined: Dec 2002
Posts: 3,841
We use both - depending on the situation. If we get an application that's missing a SS number, or something else that's needed to make an initial credit determination, we send an AA notice for incomplete application. If we don't subsequently receive the missing information, it is reported on the LAR as a denial for incomplete application.

If we have enough information to issue a conditional approval, after a certain period of time we issue an incomplete notice for the items that are still missing. If we don't receive those items by the deadline in the notice, the application is reported on the LAR as incomplete.

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#175590 - 04/02/04 05:31 PM Re: HMDA incomplete application
Tillie Offline
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Tillie
Joined: Apr 2003
Posts: 266
Thank you for the replies. As usual, your input is helpful!

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