we have started non-real estate consumer loans using a web based system. we had several people start a application but not hit submit.
our consumer people are saying this is a abandoned application and not subject to the notice of incompleteness/turndown requirements.

I am not for sure, although if the quasi-applicant doesn't hit submit maybe it is not incomplete.

In this situation, my view is to take the most conservative approach. Contact the customer and find out their intent. If nothing else, you have a chance to market yourself to the quasi-applicant, you clear a backlog from your system and show your regulator you take reg b seriously.

Charlie

This is equivalent to the customer who takes home your paper application form and fills in all the blanks--but abandons it on the kitchen table.