Good Afternoon,
I have a hypothetical scenario for you. We received an application for a HELOC 6/15/19. This is conditionally approved. On 7/10/19 we receive our Title Commitment, which reveals a judgment on the property. The loan officer agrees to give the borrower time to investigate the judgement. On 8/15/19 and 8/22/19 our officer leaves messages on the customer's cell phone looking for an update. On 9/1/19, after emailing, the officer speaks with the customer and learns the customer is facing difficulty getting an exact amount owed on the debt. The officer agrees to give the customer more time (let's say 4 weeks). After no successful contact despite repeated attempts with the customer throughout October, on 10/29/19, our loan officer decides to deny the HELOC request for "Collection Action or Judgment" pursuant to what was revealed on the Title Commitment. Normally, compliance would note an exception because we did not sent the denial letter within 30 days of receiving the information that led to the denial.
Or, is this not an exception because the decision to deny came as a result of the customer's failure to respond to contact attempts?
Thank you for your time on this one.
R. Shackleford