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#2022613 - 06/24/15 04:23 PM Reg B - 30 day notification
bstritecky Offline
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we have a prequal program where we issue the customer a prequal letter with all the subject to.... language.

When that prequal turns into an actual application (with a property) - for Reg B do we have to notify the customer of approval or denial within 30 days. In other words do we need to send the customer another approval letter?

I have a new mortgage loan officer that said at his previous employer they only every issued a prequal letter.

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#2022615 - 06/24/15 04:25 PM Re: Reg B - 30 day notification bstritecky
Kathleen O. Blanchard Offline

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Well, a prequal is not a credit approval. If you are doing a full credit approval, you have a preapproval program.

However, once the property is identified I would expect some confirmation to the customer that the final approval is now in place.
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#2022622 - 06/24/15 04:31 PM Re: Reg B - 30 day notification bstritecky
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Does it have to be in writing, or can it be as simple as a telephone call to tell them they are approved?

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#2022623 - 06/24/15 04:33 PM Re: Reg B - 30 day notification bstritecky
Kathleen O. Blanchard Offline

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Well it could be a call, but for home mortgages I prefer documentation in the file. At least put a memo in the file documenting the conversation and what was conveyed.
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#2022642 - 06/24/15 04:49 PM Re: Reg B - 30 day notification bstritecky
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Thanks smile

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#2022660 - 06/24/15 05:07 PM Re: Reg B - 30 day notification bstritecky
Richard Insley Online
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Reference: Section 1002.9(a)(1), OI #2
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#2022664 - 06/24/15 05:09 PM Re: Reg B - 30 day notification bstritecky
Kathleen O. Blanchard Offline

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That means go to the Commentary for 1002.9(a)(1), comment #2. Personally, for something as important and as regulated as a residential mortgage, I like following up in writing.

2. Notification of approval. Notification of approval may be express or by implication. For example, the creditor will satisfy the notification requirement when it gives the applicant the credit card, money, property, or services requested.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2022679 - 06/24/15 05:20 PM Re: Reg B - 30 day notification Kathleen O. Blanchard
Richard Insley Online
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Originally Posted By Kathleen B
I like following up in writing.
I agree & that would be my practice. The minimum standard stated in the OI would simply be a fall-back argument in case we missed one.
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#2022769 - 06/24/15 06:36 PM Re: Reg B - 30 day notification bstritecky
bstritecky Offline
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Thanks everyone! That was my orignial answer! I don't know when I'm going to stop hearing "my previous compliance officer said....." smile

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#2022816 - 06/24/15 08:04 PM Re: Reg B - 30 day notification bstritecky
David Dickinson Offline
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"I don't know when I'm going to stop hearing "my previous compliance officer said....."
Maybe you should reply:
"That's why they no longer work here!" or
"That's why YOU no longer work there!" smile
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#2022844 - 06/24/15 08:48 PM Re: Reg B - 30 day notification David Dickinson
bstritecky Offline
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Originally Posted By David Dickinson
"I don't know when I'm going to stop hearing "my previous compliance officer said....."
Maybe you should reply:
"That's why they no longer work here!" or
"That's why YOU no longer work there!" smile


I think i will post that on my computer screen!

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