From the GIR:
Income. Enter the gross annual income that your institution relied on in making the credit decision.
Okay….
According to an FFIEC FAQ, a satisfactory LTV is an underwriting condition. We need this condition (satisfactory LTV) met in order to make a credit decision. Following the same FAQ, we have therefore not made a credit decision if we sent a conditional approval letter requiring a satisfactory appraisal. A customer can withdraw right up to this point because a credit decision has not been made. If we receive a satisfactory appraisal and commit the loan and the customer does not close the loan we code it as approved but not accepted. We don’t code it as a withdrawal even if the customer says the otherwise magic words (“Please withdraw my loan”) because having issued the commitment letter we made a credit decision.
Following this logic, shouldn’t we code income as "NA" for all withdrawals and files closed for incompleteness because a credit decision was not made?
Last edited by Blue78; 02/27/13 06:55 PM.
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