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#2142400 - 08/17/17 04:09 PM Would this be considered a withdrawal?
mdog76 Offline
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Joined: Jan 2007
Posts: 645
Sorry if this seems simple, but if at the closing table the customer decided to payoff a loan instead of following through with the renewal, would this be considered a withdrawn app?

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Lending Compliance
#2142420 - 08/17/17 04:58 PM Re: Would this be considered a withdrawal? mdog76
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,459
Florida
Approved but not accepted!

The bank approved the loan - it never closed.
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#2142426 - 08/17/17 05:11 PM Re: Would this be considered a withdrawal? mdog76
mdog76 Offline
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Joined: Jan 2007
Posts: 645
Would that require an adverse action notice or anything?

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#2142441 - 08/17/17 05:44 PM Re: Would this be considered a withdrawal? mdog76
Truffle Royale Offline

10K Club
Joined: Jul 2003
Posts: 17,359
no. You're not acting adversely on the application. You approved the loan. The borrower is opting not to accept your approval.

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#2142445 - 08/17/17 05:48 PM Re: Would this be considered a withdrawal? mdog76
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,333
Not from a regulatory perspective. We send a "withdrawn notice" produced by our doc prep software, same as an adverse action notice. It's just good documentary evidence of what happened and when.
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#2142522 - 08/17/17 09:49 PM Re: Would this be considered a withdrawal? mdog76
Rocky P Offline
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Joined: Jun 2003
Posts: 7,459
Florida
Swiggles, I advise clients against any paperwork not required by regulations. Fully documented yes. Banks can unwillingly be creating exceptions where none legally exist, and if it looks or seems like an Aan, it could confuse both applicants and employees.
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Integrity. With it, nothing else matters. Without it, nothing else matters.

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#2142569 - 08/18/17 01:24 PM Re: Would this be considered a withdrawal? mdog76
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,333
I agree, Rocky P....however, not my call. I would like it a lot better if the withdrawn notice was simply created and placed in the file as a method of closing out the file....but NOT mailed to the applicant. I DO like the idea of lenders being forced to go into the software and perform a task to close out every file....either send a denial or prepare a withdrawn notice for the file (which establishes the date of withdrawal....important for HMDA).

Preparing the withdrawn notice also triggers a second review to make sure that the withdrawal is not a denial in disguise.
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The more you sweat in training, the less you bleed in battle.......

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