our LO will send out early disclosures and the applicant will just never respond to us.
We include a cover letter that informs the applicant what information we need to move forward with the application. We inform them that if we don't receive the information by a certain date then we will assume they have chosen not to proceed with the loan request and report it as closed for incompleteness.
I know I've had this discussion before but I'd like to take this a little further to see how you finish this process. We are also looking to implement where we do a cover letter requesting docs etc in order to proceed with a drop dead date...say like 20 days. So here is my thought dilemmas and would like to hear more about everybody that does it this ways process.
So lets say the Application was taken on 12/1/2017. We've given this Borrower the cover letter stating all we need by 12/21/2017 to proceed. REGB 30 day notification has been satisfied and all is good.
Now its 2/15/2018 and we've already received enough information to send to UW for a "Conditional Approval" and the file ihas been sent back to Processing Dept to wait on the additional conditions to be sent in to proceed along with waiting on Title/Appraisal etc.
Time rocks on and Borrower is now radio silent. Now before I ask this next question I want to put out there that the only time we ever code a file as Approved Not Accepted is when we have a FINAL Approval...that is per our Compliance Dept, so I can't even consider this option when I ask my question.
Mgmt wants us to go back and close out this file as Incomplete based upon that original letter in our cover letter, which in this case would be 12/21/2017 and this date would code as our Final Action date as Incomplete. My argument to them is that we absolutely can NOT do this as this will affect our 2017 HMDA LAR that's could possibly have already been filed or in the process of being scrubbed and will more than likely be missed. I said if we are that far along in the process and are still requiring more information that we've not received to move to Final Approval and the Borrower has gone silent, then we need to send out another NOI and Incomplete based upon that NEW NOI we've sent with a new drop dead date, but they state they want to get away from having to send additional NOI's. I honestly just don't see how this can be done but wanted to check with all of you who have implemented these procedures and get your thoughts.