We're evaluating whether we've met ECOA's timing requirements for notifications. 1002.9(a)(1) The regulation states notification of approval may be express or by implication. For example, the creditor will satisfy the notification requirement when it gives the applicant the credit card, money, property, or services requested.
It does not reference conditional approval (customary or with outstanding creditworthiness conditions) as an approval. When calculating the 30 day requirement from application or completed application, how would we define "approval"? The above referenced definition appears to suggest that it's a final approval (i.e., customary closing conditions).