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#2013975 - 05/13/15 09:44 PM Corrective Adverse Action Letters?
Doin it right Offline
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If an error is discovered on an Adverse Action Notice that has already been sent to an applicant, such as listing the wrong denial reason, an invalid or inapplicable denial reason, or there were denial reasons missing from the letter, what is the appropriate action to take? Is it appropriate and/or required that a corrected letter be sent out? And, if so, what would generally be an acceptable timeframe to do so? Also, if it is doscovered that an AAN wasn't sent out and should have been, then what?

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Lending Compliance
#2014122 - 05/14/15 05:35 PM Re: Corrective Adverse Action Letters? Doin it right
Doin it right Offline
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Bump - Anyone?

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#2014125 - 05/14/15 05:46 PM Re: Corrective Adverse Action Letters? Doin it right
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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I would correct the reasons and reissue with an explanation that the errors were noticed in a file review (or similar language).

You might consider going back to the last exam. I have seen examiners require letters going back a couple of years if there were defects.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2014126 - 05/14/15 05:46 PM Re: Corrective Adverse Action Letters? Doin it right
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
And fix the process, of course.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2015053 - 05/19/15 08:12 PM Re: Corrective Adverse Action Letters? Doin it right
NotALawyer Offline
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NotALawyer
Joined: Nov 2001
Posts: 455
Responding to the "acceptable timeframe" question - this is a two-parter. The first part is how long it took for the problem to surface and be identified. The examiners could be critical of the second- (compliance) and third-line (internal audit) of defense and their ability to identify deficiencies.

The second part is how long it took from the time the issue was identified to the time the corrective letters were sent. Too long and management can be criticized for not taking prompt action.

"With all due haste" would be a good measuring stick.

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