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#2124053 - 03/28/17 10:58 PM Denial or Incomplete Application?
crcmnot Offline
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Joined: Sep 2016
Posts: 351
I just received a file with a note to send the AAN to applicant. Application received 3/20 and credit report pulled 3/20. This would have been for an interim construction loan; however the application (nor file) lists a property address or location for the collateral. Under TRID, this would have been an incomplete application as we did not have all six pieces. I can only assume that my team did not get this file before 3/23 to send out an LE because we did not have all six pieces. The officer is denying based on DTI and lack of Income Reserves; credit score was good and not a factor.

Can I send out an AAN for the denial or is this really an incomplete application under Reg B due to the missing property address/location and I need to send the notice for incompleteness? Thank you.

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#2124067 - 03/29/17 12:48 PM Re: Denial or Incomplete Application? crcmnot
Inherent_Risk Offline
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Joined: Jan 2017
Posts: 570
The definition of an application is different for just about every regulation. Just because it is not an application under TRID doesn't mean you don't have enough to deny under ECOA. I definitely would not send a NOI to a borrower you already know you are going to deny. That would be a waste of time for you and the borrower.

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#2124070 - 03/29/17 01:09 PM Re: Denial or Incomplete Application? crcmnot
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Sounds like a pre-approval or pre-qualification program. Just make sure your credit policies address this sort of a program so everyone is treated equally.
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#2124105 - 03/29/17 03:01 PM Re: Denial or Incomplete Application? crcmnot
crcmnot Offline
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Joined: Sep 2016
Posts: 351
Thank you both for your responses.

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