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#2090826 - 08/01/16 02:39 PM Loan Denial after 30 days
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
We initially approved a home purchase. Since approval, we have learned the applicant is no longer working and can verify all deposits in her account have stopped. We have called her employment to verify employment but they will not (family business). She is the receptionist and hasn't answered the phone at all. Her current loan with us is now 60 days past due. Can we deny if we are already in the loan process?
Last edited by ahkcompliance; 08/01/16 02:40 PM.
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Lending Compliance
#2090832 - 08/01/16 02:52 PM Re: Loan Denial after 30 days ahkcompliance
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Why not?
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#2090837 - 08/01/16 02:56 PM Re: Loan Denial after 30 days ahkcompliance
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
I was thinking we are pass the 30 day deadline for Reg B purposes of denying within 30 days of completed application. We have the file documented well for our reasoning.

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#2090840 - 08/01/16 02:58 PM Re: Loan Denial after 30 days ahkcompliance
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
This is the entire reason behind why many secondary market investors require a second verification prior to closing, to find out changes such as this. Same with ATR...It can change the entire original underwriting.
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#2090856 - 08/01/16 03:47 PM Re: Loan Denial after 30 days ahkcompliance
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
Thanks for your input!

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#2090860 - 08/01/16 04:00 PM Re: Loan Denial after 30 days ahkcompliance
Rocky P Online
Power Poster
Joined: Jun 2003
Posts: 7,650
Florida
The 30 days is revolving. Once you determined (at 2nd verification) that there was a change, the bank has 30 days to deny.

Completed application means everything the bank needs to make a decision. If the credit bureau is bad, it's 30 days from receipt. Next step - appraisal, if that is low, 30 days from its receipt - keep going until closing, or a reason to stop.
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#2090869 - 08/01/16 04:15 PM Re: Loan Denial after 30 days ahkcompliance
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
Thanks Rocky!

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#2091021 - 08/02/16 02:06 PM Re: Loan Denial after 30 days ahkcompliance
Clareb Offline
Junior Member
Clareb
Joined: Jan 2014
Posts: 30
Massachusetts
You took an action (approval ) within 30 days. You are well within your right to deny based upon unverifiable information.

ETA: you can also deny her based upon her credit history with your organization (60 days late)
Last edited by Clare B; 08/02/16 02:10 PM. Reason: ETA
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