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#2139545 - 07/26/17 02:19 PM Action Taken Date Question
AW27 Offline
New Poster
Joined: Jan 2017
Posts: 22
I'm tasked with "cleaning up" our loans pipeline and making sure everything is in order.....In our LOS there are many loans that have no status, (meaning I can't tell if they're denied, closed, withdrawn, etc)......These loans have subject properties, addresses, income, they are full applications and they were created within this year so they are HMDA reportable. When I ask my loan officers about these I have gotten responses that they don't remember what happened with it and they can't give me an action taken or an action taken date.....The few times that they do respond they will tell me "Withdrawn * as of today's date*" which obviously is not true....
I know this is probably a management issue but from a compliance standpoint does anyone have any suggestions? This is giving me a HMDA nightmare

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#2139560 - 07/26/17 03:07 PM Re: Action Taken Date Question AW27
Nickel0207 Offline
Junior Member
Joined: Jul 2017
Posts: 30
If they were denied, denial letters would have been sent with the reason for denial. Are those being sent at least? Otherwise, you have a few issues going on - not just HMDA to worry about.

Can you start with tracking those down? You are going to have to start scrubbing the files. Can you get copy of correspondence? Definitely sounds like you need to have a sit-down with Management. Good luck!

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#2139586 - 07/26/17 04:47 PM Re: Action Taken Date Question AW27
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,658
Florida
Starting from the beginning, the department is sorely in need of policies, procedures, leadership and training, both from a HMDA and LOS perspective.

Systems usually have timing reports - someone failed to use them. Like Nickel, there is a whole world of ECOA issues if timing requirements are not met - ECOA and Fair Lending. Identify each application that has not been funded. Eliminate the ones with adverse action letters, or notices of incompleteness. Withdrawn is a lousy term, because it means one thing to HMDA, and has a meaning of "I have no idea what happened, so find a home for it" to a loan officer.

Get legal involved. If there are a number that exceeded the 30 day period, management needs to be involved for guidance and preventive action for examiners. Compliance should not be holding the stick for the LO's. Then Train the ones that have not been fired.
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