What is your institutions definition of a completed application (for Reg B) on commercial loans? Written application? Receipt of financial statement? Loan approval? I'm trying to put something tegether for policy. We do not use a written loan application on comm'l loans. Thanks

A completed ap will be when the bank has all it needs to make a credit decision(same definition as consumer). Financials, appraisals, etc.

Many banks issue a conditional approval subject to UCC searches, various due diligence, perhaps appraisals, etc.

So would I have any issue with setting our policy at "loan approval" as the definition of completed application?

Well, that makes no sense to me since you need a completed ap to get a full unconditional loan approval. Unless you are referring to a document?

Sorry I am being so obtuse! I am trying to set a policy and determine how to set the "application date" to start the clock ticking on these three days. When you have loans that can be made under a lenders authority and loans that have to go to loan committee where do you draw that line that you now have an application?

What three days? Any three day disclosure is not based on a "complete" application.

I'm sorry. I'm having trouble with this one, as you can see. The question relates to the new required disclosure of the right to receive a copy of the appraisal. I had placed the question in here to see if anyone had a general description of "completed application". It would be easier if we obtained applications from our commercial and agricultural customers but we don't. How/where do I start the clock?

You should not tie the appraisal disclosure to a "completed application" date. Tie it to an initial (which may be incomplete) application, such as when you received a loan request. The lender gets a phone call or meets with the customer, they say they need a loan for such and such, the bank documents that the call or meeting took place and lets the customer know what else is needed to move forward with the request.

You could start there.

Possibly the bank won't do anything until financials are received; you could tie it to that date. What do you do for HMDA and Reg B otherwise? Be consistent.

But don't wait for a "completed application". That could be much too late in the process.