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#1798520 - 03/26/13 09:04 PM Reopen application closed for incompleteness?
MMA Offline
New Poster
Joined: Aug 2012
Posts: 21
If a bank closes a loan application due to incompleteness (utilizing the incomplete notice in accordance with the section below), and then at some point in the future (a week, a month, etc), the applicant comes back with the missing information, should this be considered a new application or is it acceptable practice to "reopen" the existing application that was previously closed?

"(2) Notice of incompleteness. If additional information is needed from an applicant, the creditor shall send a written notice to the applicant specifying the information needed, designating a reasonable period of time for the applicant to provide the information, and informing the applicant that failure to provide the information requested will result in no further consideration being given to the application. The creditor shall have no further obligation under this section if the applicant fails to respond within the designated time period. If the applicant supplies the requested information within the designated time period, the creditor shall take action on the application and notify the applicant in accordance with paragraph (a) of this section."

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#1798523 - 03/26/13 09:09 PM Re: Reopen application closed for incompleteness? MMA
TMatt87 Offline
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TMatt87
Joined: May 2011
Posts: 2,004
Idaho
We consider it a new application, however, I believe it is allowed to be reopened. Be careful that the file wasn't closed in one year and then reopened in the next. That could create reporting issues.
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#1798533 - 03/26/13 09:22 PM Re: Reopen application closed for incompleteness? MMA
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Yes, it can be reopened. It is up to the bank. I find that most start over but I do have a client that keeps the same application number.
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#1798561 - 03/26/13 11:03 PM Re: Reopen application closed for incompleteness? MMA
Truffle Royale Offline

10K Club
Joined: Jul 2003
Posts: 17,410
We would treat it as a new application no matter when it came in.
It's just cleaner that way.

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#1798647 - 03/27/13 01:42 PM Re: Reopen application closed for incompleteness? MMA
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,481
Midwest
Our bank does allow us to reuse an application but it must be less than 6 months old. If we were to do this, I would have the lender document when the new piece of info arrived and date teh application. We will usually have the borrower sign the application again just stating that everything is still correct.

I don't like to do it this way but we have on occassion usually for frequent borrowers.

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