Thread Options
#2235146 - 04/17/20 06:50 PM Don't decline due to covid19
Florist Gump Offline
New Poster
Joined: Feb 2020
Posts: 12
Greetings all,

I was instructed by upper management that declines due to covid19 are not acceptable because it is currently affecting everyone. Secondly, denying due to "unfavorable economic/industry conditions" is also unacceptable due to it's broadness and lack of specificity. (ยง1002.9(a)).

Declines should be due to specific reasons like "unable to verify income" (one example) or due to moratorium, if that's the case.

Thoughts?

Return to Top
Fair Lending
#2235162 - 04/17/20 08:06 PM Re: Don't decline due to covid19 Florist Gump
RockChucker, CAMS Online
Diamond Poster
Joined: Jul 2013
Posts: 1,625
The Country
When you say "due to Covid19" what exactly does that mean? Is that a decline because the lobby of the bank is closed? Or is it a decline because the person lost their income because their employer closed up shop? Is it a decline because the PPP ran out of money? Just trying to understand to provide a meaningful answer.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

Return to Top
#2235169 - 04/17/20 08:44 PM Re: Don't decline due to covid19 RockChucker, CAMS
Florist Gump Offline
New Poster
Joined: Feb 2020
Posts: 12
Hey Rock,

Your point has been made with your response. We have been receiving adverse action notices from business units with "decline due to covid19" as the ONLY reason. Super broad as pointed out by the reasons you have provided, and I suppose this is why we received that as instruction. Luckily (or not), our p&p requires the business units to have Compliance approve adverse action notices before going to the applicant.

Thanks.

Return to Top
#2235271 - 04/20/20 06:11 PM Re: Don't decline due to covid19 Florist Gump
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Now that I understand your first post I agree that "decline due to covid19" is not a specific reason. I'm not sure what "due to moratorium" means. Reg B requires specific reasons.
_________________________
David Dickinson
http://www.bankerscompliance.com

Return to Top
#2235279 - 04/20/20 07:40 PM Re: Don't decline due to covid19 Florist Gump
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,351
Florida
Florist, what the others are saying.
The AAN reason for decline is to help the applicant correct the situation they are being declined for so they can get the loan.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

Return to Top