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#1926178 - 05/23/14 03:21 PM Clarification of action taken date
Ski Offline
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Joined: May 2003
Posts: 639
South Louisiana
We have a new mobile home program where a new consumer loan officer works with mobile home dealers who refer potential applicants (NOT indirect lending). Anyway, LO will take telephone application and decision loan same day. Some are denied due to "Credit score too low for amount requested", "Income insufficient for amount of credit requested", "Limited credit experience".

But a "Notice of Action Taken and Counteroffer" is sent giving them 30 days from date of AAN/Counteroffer for "Maximum loan amount of $XX,XXX.XX - that loan amount will bring DTI down", "Will loan up to 85% of collateral value", "Would reconsider with acceptable co-signer".

If the applicant does not respond at the end of the 30 day period, is the Action Taken date the date of denial or the date the counteroffer expired?

Thanks in advance.

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#1926182 - 05/23/14 03:24 PM Re: Clarification of action taken date Ski
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
First - this is an unacceptable reason under the specificity rules of Regulation B :"Credit score too low for amount requested".

It would be the date of your adverse action notice.
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#1926184 - 05/23/14 03:28 PM Re: Clarification of action taken date Ski
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
"Credit score too low for amount requested",

Under Reg. B that is not a legitimate reason for denial. You have to give specific reasons why the credit score is too low, such as derogatory credit.

Your date of action is the date you took final action. In our case the date we send the AAN or AAN/Counteroffer is the date of our final action. If it's a notice of incompleteness our date of final action is when we close the file after the date stated on the notice of incompleteness to provide the needed documentation.
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The opinions expressed are mine and they are not to be taken as legal advice.

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