With regard to consumer purpose, non-RE loan applications (e.g. consumer purpose loan secured by vehicle), applicant completes our application online, however he/she doesn't provide all the necessary information for us to make a credit decision. We generally call the applicant back regarding the lacking information, and in some situations we hear nothing back from the applicant. In these situations, should we instead be notifying the customer with a notice of incompleteness with a request to provide the missing information by a specific date? Or do we just turn the loan down (deny) for incompleteness? How do others handle this? And if we simple call them and ask them to call us back (in other words we don't specify what additional information we need, does this make a difference) on whether we can consider the loan incomplete or not? Thanks for any feedback.

Either of these two options are permissible and you will find that some banks take one approach while other banks take the other approach.

Ok, do we need to be consistent with our approach? And if we tell them we need the missing information by such and such date, how long do most banks give?

When we call these applicants, we typically leave a very broad message, basically just asking the applicant to call _____ (loan officer's name) in regard to your online application. We don't provide any specifics about the additional information needed. So how we proceed is entirely up to us, when they don't reply? Either send AAN to deny for incompleteness or send Notice of Incompleteness requesting for the additional information?

No, you don't have to be consistent, but that could be confusing for staff unless they really understand the rules.

To clarify, you have to "tell them" in writing, in accordance with the requirements set forth in Regulation B. From my experience, most banks give 30 or 60 days.

Yes, as long as you do it within the time frames set forth in Regulation B.

Why does your system allow incomplete applications to be submitted, or is that that the applicant puts in incomplete information?

https://www.bankersonline.com/regulations/12-1002-009

Look at 9(a) 3&4 and 9(c) as to incomplete applications.

Well, it might depend on whether or not the application is subject to TRID. You get the six pieces of information, you cannot force them to not submit the application pending entry of additional information. Other loans, you can require whatever you want before they are allowed to submit the application.

My initial post states for consumer purpose, non RRE loan requests, so no, these online applications are not subject to TRID.

Thanks Andy. So we are looking to send a notice very similar to Form C-6 - Sample Notice of Incomplete Application and Request for Additional Information. If we have pulled a credit report on this applicant, then are we also required to provide the credit bureau information under FCRA? Or is this information not required to be disclosed to the application on an application with incomplete information? Thanks.

If you are just sending the notice of incomplete application (according to Reg B), then the FCRA information is not required on that notice. On the other hand, if you were denying for an incomplete application, you would provide the FCRA info on the AA notice.