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#1819954 - 06/04/13 02:59 PM Timing of Adverse Action Notices
KDF Offline
Member
KDF
Joined: Jul 2009
Posts: 79
Minnesota
The bank is required to provide notification of approval or denial of a loan request within 30 days.

What do we do if the lender does not receive information required to make a credit decision, i.e. an appraisal does not come back in time?

Would we satisfy the Regulation B requirements by contacting the customer with an approval subject to the appraised value --then what do we do if the appraised value isn't sufficient?
Send an adverse action notice then?

What are other banks doing?
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"Sometimes that light at the end of the tunnel is a train."
Charles Barkley

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Lending Compliance
#1819981 - 06/04/13 03:20 PM Re: Timing of Adverse Action Notices KDF
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,364
That's how I do it.
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#1820158 - 06/04/13 06:51 PM Re: Timing of Adverse Action Notices KDF
Dcomply Offline
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Joined: Aug 2012
Posts: 57
Conditional Approval Letter when the appraisal has not be received, then an Adverse Action notice if the appraisal is received and is insufficent.

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#1820162 - 06/04/13 06:57 PM Re: Timing of Adverse Action Notices KDF
TMatt87 Offline
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TMatt87
Joined: May 2011
Posts: 2,004
Idaho
We just document in the file the reason action wasn't taken. Examiners have been OK with that so far.
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#1820622 - 06/05/13 06:42 PM Re: Timing of Adverse Action Notices KDF
KDF Offline
Member
KDF
Joined: Jul 2009
Posts: 79
Minnesota
Thanks all for you help!
_________________________
"Sometimes that light at the end of the tunnel is a train."
Charles Barkley

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