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#2225614 - 11/14/19 01:57 PM Re: Application received on Sunday Nico
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
Actually, I should have referred to receiving an application via our on-line application system at 11 PM, not email. Thanks for pointing out that typo Randy.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2225626 - 11/14/19 04:16 PM Re: Application received on Sunday Nico
Truffle Royale Offline

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Joined: Jul 2003
Posts: 17,400
imho, just because an application is uploaded doesn't mean it was received. That application is non-existant until a live body opens it and starts processing it. Therefore, after hours, over a weekend and/or a holiday all would be dates that do not start the clock. Ex: application uploaded at 11pm last Friday. Bank closed Saturday, Sunday, Monday. There's three days. Would your system say you missed timely delivery of the LE or would it mark Tuesday as the receipt date? Here, nobody would know it existed till Tuesday and, after having an LO sign it, that's the date that would be entered into the LOS.

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#2243238 - 09/29/20 01:43 PM Re: Application received on Sunday Truffle Royale
Compliance NABW Offline
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Joined: Oct 2015
Posts: 1,669
"That application is non-existent until a live body opens it and starts processing it."

I wouldn't want to count on that line of reasoning. What if live body doesn't open it for 3 days? It's still not existent? Did anybody ever ask the CFPB about this topic?

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#2243255 - 09/29/20 03:41 PM Re: Application received on Sunday Nico
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I have just sent an inquiry with a bunch of scenarios involving written, emailed and on-line applications "received" at weird, non-business-hours or on non-business days.

One thing I keep failing to do is to draft my questions to the Bureau in a form I can retain and then paste them into the Bureau's webform for questions. So I have no actual written record of what I asked.
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John S. Burnett
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Fighting for Compliance since 1976
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#2243282 - 09/29/20 05:19 PM Re: Application received on Sunday Nico
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,669
Great . . . please post if you ever get a response.

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#2243298 - 09/29/20 08:41 PM Re: Application received on Sunday Nico
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
David Dickinson just reported on a rather complex HMDA question he sent in on Tuesday of last week, and he got a call with the answer on Friday == three days later. So I am optimistic..
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2243685 - 10/07/20 01:37 PM Re: Application received on Sunday Nico
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
My optimism is fading. It's been 6 business days and counting.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2243776 - 10/08/20 01:30 PM Re: Application received on Sunday John Burnett
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,669
They don't want to mess with this one, lol.

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