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#2156403 - 12/07/17 02:34 PM Reg B and Commercial Lending
Soccer Offline
Diamond Poster
Joined: Jan 2010
Posts: 1,028
Utopia
I'm looking for some insight as how your commercial loan area stays within the 30 notification requirements. We struggle here with it because the lenders are always looking for additional information and the volume of loans that the underwriters look at tend to cause delays. I have explained that if they have incomplete applications to send the letters and that will at least give them some additional time.
Any thoughts are welcomed.
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General Discussion
#2156441 - 12/07/17 04:40 PM Re: Reg B and Commercial Lending Soccer
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,658
Do you use conditional approvals?
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2156450 - 12/07/17 04:57 PM Re: Reg B and Commercial Lending Soccer
ComplyWithMeeee Offline
Junior Member
Joined: Jul 2016
Posts: 30
NOIs with ECOA verbiage
Conditional Approvals
Use of an 'Application Complete' date in LOS

Each of these are viable options depending on the progress of the loan.

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#2156490 - 12/07/17 06:57 PM Re: Reg B and Commercial Lending Soccer
Soccer Offline
Diamond Poster
Joined: Jan 2010
Posts: 1,028
Utopia
No conditional approvals.
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Everything happens for a reason

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#2156578 - 12/08/17 03:38 PM Re: Reg B and Commercial Lending Soccer
Monster Offline
Platinum Poster
Joined: Sep 2015
Posts: 500
Have them notate the file with explanations of what they still need from the applicants and conversations.

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#2157196 - 12/13/17 09:53 PM Re: Reg B and Commercial Lending Soccer
Carl R Offline
New Poster
Joined: Nov 2017
Posts: 7
The following is an excerpt from the Reg. B Official Staff Commentary:
Timing of notification. A creditor subject to §202.9(a)(3)(ii)(A) is required to notify a business credit applicant, orally or in writing, of action taken on an application within a reasonable time of receiving a completed application. Notice provided in accordance with the timing requirements of §202.9(a)(1) is deemed reasonable in all instances.
With respect to consumer purpose applications, we’ve always started the 30-day clock upon receipt of the application. Not so with business purpose.
The key is to document receipt of all information needed to make a decision. The “reasonable time” reference in the Commentary recognizes the challenges of obtaining a complete business app and offers some wiggle room. However, it appears to apply to businesses with revenue in excess of $1M.
The key is documenting follow-up.

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