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#1915101 - 04/16/14 07:52 PM Withdrawn Loans
FNB Offline
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Wondering the approx number of consumer loan withdrawn files your institution has on an annual basis? And the size of your institution. Do you count a prequal as an application, track and withdraw if needed?
Last edited by helpfnb; 04/16/14 07:52 PM.
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#1915105 - 04/16/14 08:04 PM Re: Withdrawn Loans FNB
#Just Jay Offline
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Unfortunately, you will get nothing of value from that line of questioning since there are far too many business models represented through our banks to give you any real sort of true and useful information.

That said, IMO, a bank should have very few withdrawn applications since the window to withdraw an application, between the submission of the application and prior to any credit decision being made, is so small.

Is there a more targeted question or issue you are after?
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#1915113 - 04/16/14 08:11 PM Re: Withdrawn Loans #Just Jay
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Thanks, what I am looking for is, when you "prequal" someone, do you consider this a Reg B application and start tracking Notice of Incomplete timeframe, and how many of these do you have that never materialize into anything?

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#1915118 - 04/16/14 08:26 PM Re: Withdrawn Loans FNB
#Just Jay Offline
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Prequal, no, I do not, and we generally refrain from doing prequals.

We will do so for preapprovals though.
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#1915119 - 04/16/14 08:28 PM Re: Withdrawn Loans FNB
Kathleen O. Blanchard Offline

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Prequals should have an "end" date after which it no longer applies and the bank closes it out.
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#1915127 - 04/16/14 08:42 PM Re: Withdrawn Loans FNB
BankingNut Offline
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Originally Posted By: helpfnb
Thanks, what I am looking for is, when you "prequal" someone, do you consider this a Reg B application and start tracking Notice of Incomplete timeframe, and how many of these do you have that never materialize into anything?


It is going to be really hard for you to find this information because the best source of withdrawal information is going to be your HMDA LAR, or you can order HMDA information from the CFPB.

I think, and Just Jay can tell me if I am off base, that he is referring to approved and not accepted under HMDA definitions. Depending on how you treat applications, we only call a full underwriting approval an "approval" under approved and not accepted and thus actually have a significant number of withdrawals.

I differentiate between a preliminary approval and a final approval.

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#1915150 - 04/16/14 09:36 PM Re: Withdrawn Loans Kathleen O. Blanchard
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Originally Posted By: Kathleen B
Prequals should have an "end" date after which it no longer applies and the bank closes it out.


Do you then consider these withdrawn applications?

What I am dealing with is lenders are doing a "prequal" but are not considering it a reg b application, so nothing is ever followed up on, or tracked. We have VERY few withdrawn or denied files a year, and it is a big concern of mine, but am getting push back that these aren't "applications".

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#1915163 - 04/16/14 10:36 PM Re: Withdrawn Loans FNB
straw Offline
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Do you have a definition for application? Reg B allows each institution to determine what is an application.

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#1915214 - 04/17/14 01:38 PM Re: Withdrawn Loans BankingNut
#Just Jay Offline
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Cheeseheadland
Originally Posted By: BankingNut
Originally Posted By: helpfnb
Thanks, what I am looking for is, when you "prequal" someone, do you consider this a Reg B application and start tracking Notice of Incomplete timeframe, and how many of these do you have that never materialize into anything?


It is going to be really hard for you to find this information because the best source of withdrawal information is going to be your HMDA LAR, or you can order HMDA information from the CFPB.

I think, and Just Jay can tell me if I am off base, that he is referring to approved and not accepted under HMDA definitions. Depending on how you treat applications, we only call a full underwriting approval an "approval" under approved and not accepted and thus actually have a significant number of withdrawals.

I differentiate between a preliminary approval and a final approval.


I was until the OP clarified what they were after with the post you quoted from them. Then I intentionally stayed away from the HMDA aspect, and answered based on what we define as an application. Unless the OP is intermingling the terms prequel and preapproval (two very different things), they are not an application for HMDA purposes, and Kathleen and Straw and given the OP excellent points to review and consider.
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#1915224 - 04/17/14 02:03 PM Re: Withdrawn Loans FNB
Kathleen O. Blanchard Offline

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Originally Posted By: helpfnb
Originally Posted By: Kathleen B
Prequals should have an "end" date after which it no longer applies and the bank closes it out.


Do you then consider these withdrawn applications?

What I am dealing with is lenders are doing a "prequal" but are not considering it a reg b application, so nothing is ever followed up on, or tracked. We have VERY few withdrawn or denied files a year, and it is a big concern of mine, but am getting push back that these aren't "applications".


Not for HMDA or any other regulatory purpose.
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The HMDA Academy
www.kaybeescomplianceinsights.com

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