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#2064511 - 02/16/16 08:27 PM HMDA Action Closed Incomplete
MSB05MS Offline
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Joined: Jan 2008
Posts: 97
I am scrubbing and reviewing an application that had an incomplete letter issued within 30 days of application. The letter says that if the required items are not provided by 1/29/15, the file will be given no further consideration to the loan request. The file was closed incomplete as of 2/24/15. Is this acceptable to wait so long after the specified date to close the file incomplete or should it have been done sooner? Our standard practice is to close the file the next working day after the drop date specified. Help please.

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#2064515 - 02/16/16 08:43 PM Re: HMDA Action Closed Incomplete MSB05MS
SnuffytheSeal Offline
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Joined: Oct 2009
Posts: 270
State of Confusion
We usually give them 10 days not 30 then incomplete the loan on the 11th day.
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#2064517 - 02/16/16 08:50 PM Re: HMDA Action Closed Incomplete MSB05MS
MSB05MS Offline
Member
Joined: Jan 2008
Posts: 97
Are you saying you close incomplete 10 days after the date specified, or you give them 10 days in the letter of incomplete? I am concerned with the time lapse after the date specified not being sooner, since we normally close incomplete the following working day after our drop date specified in the letters. From what I read in HMDA GIR, it just says if the applicant does not respond within the period of time specified in the notice.

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#2064538 - 02/16/16 09:43 PM Re: HMDA Action Closed Incomplete MSB05MS
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
For applications (including preapproval requests) that did not result in an origination, enter the date when the final action was taken (e.g., the application was denied or the file was closed for incompleteness) or when the notice of the action was sent to the applicant..

If your policy is to close one day after the expiration then your loan officer owes you an explanation why it took them 30 days after the expiration to close the file.
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The opinions expressed are mine and they are not to be taken as legal advice.

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