We have a few applications that were received close to 30 days ago. All items needed to make a credit decision were received, except for the appraisals.

We cannot issue a Notice of Incomplete Application because the providing the appraisal is outside of the applicant's control. To stay within the 30 day window to provide notice under Reg B, do we have to deny these applications for unable to verify collateral, since we cannot make a credit decision?

Thanks in advance.

"All items needed to make a credit decision were received, except for the appraisals."

You are required to notify the applicant of the action taken within 30 days of receiving a completed application. The statement above indicates that you do not yet have a completed application, so the 30 day clock is not yet ticking. Your bigger issue may be determining why it's taking so long to get the appraisals.

I agree with TomS that since you said you need the appraisal to make the credit decision that your clock (probably) doesn't start until you get the appraisal back.

That said, this is a tricky area as Reg B isn't abundantly clear on when the clock starts and, in fact, leaves the definition of application wide open for financial institutions to have different definitions of a completed application. As some auditors and/or examiners don't always see things the same way, some financial institutions just provide a conditional approval in order to avoid any discussions about the 30-day rule.

Again, this is a complicated topic, but if you are interested in more info on this, here is an article that explains my take on this: https://www.compliancecohort.com/blog/regulation-b-30-day-rule.

Thank you both!