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.