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#1785106 - 02/12/13 03:44 PM Form for application withdrawn
HR Banker Offline
Diamond Poster
Joined: Oct 2002
Posts: 1,027
Would there be a problem with using the adverse action notice for withdrawn applications and marking the "other" box and putting customer withdrew application?

The heading on that section is "Principal reasons for credit denial, termination or other action taken concerning credit".

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Lending Compliance
#1785121 - 02/12/13 03:57 PM Re: Form for application withdrawn HR Banker
Rocky P Online
Power Poster
Joined: Jun 2003
Posts: 7,659
Florida
Problem - YES! The AAN form is for adverse action.

The bank did not decide, the customer did. The bank does not need to tell the customer what they said. To document, put a simple memo in file with the date, and basic information.

example - 2/12/13 John called me today and withdrew his application. He's borrowing the money from his parents.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

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#1785126 - 02/12/13 04:00 PM Re: Form for application withdrawn HR Banker
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
I do not like using the vendor supplied forms for "confirming" withdrawn loans, especially when created in an origination system that then attaches the credit score disclosures.

It is just simply creating confusion for customers (and bankers) who "learn" that this is adverse action. It is not.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1785151 - 02/12/13 04:51 PM Re: Form for application withdrawn HR Banker
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,351
Our AAN process is centralized. We DO use the software form to document the file. However, the form is title "Notice of Action Taken." And the action is disclosed as a withdrawn file. We do not send a copy to the customer.
_________________________
The more you sweat in training, the less you bleed in battle.......

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#1785157 - 02/12/13 05:02 PM Re: Form for application withdrawn swiggles
HR Banker Offline
Diamond Poster
Joined: Oct 2002
Posts: 1,027
Thanks everyone for their help.

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