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#2199919 - 12/05/18 06:58 PM Applicant dies - how to report
laf0915 Offline
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We received an application and 5 days after that, our customer passed away. We had pulled credit and sent out the loan estimate and other disclosures. Can this be reported as withdrawn even though it obviously was not expressly withdrawn by applicant. We would document this via a memo stating that we are considering it withdrawn due to the death of the applicant. The other option I was considering is reporting it as "file closed for incompleteness". Any suggestions?

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#2199920 - 12/05/18 07:11 PM Re: Applicant dies - how to report laf0915
raitchjay Offline
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OK
I don't know of any explicit guidance, but i think closed for incompleteness actually is most easily defended.....if you had sent the notice of incompleteness that is.
Last edited by raitchjay; 12/05/18 07:12 PM.
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#2199927 - 12/05/18 08:10 PM Re: Applicant dies - how to report raitchjay
laf0915 Offline
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We did not send a formal notice of incompleteness because it didn't seem appropriate since we knew she was deceased. Our letter that goes out with the loan estimate states that we need intent to proceed and also the verification items we need and says that if we do not receive the requested information within ten days, no further consideration will be given t the application. Would that be enough to defend reporting it as "file closed for incomplete"

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#2199938 - 12/05/18 10:43 PM Re: Applicant dies - how to report laf0915
Truffle Royale Offline

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That IS a notice of incompleteness, laf0915. It has all the information you need to mark this 'incomplete' for HMDA.

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#2199964 - 12/06/18 03:12 PM Re: Applicant dies - how to report laf0915
burke116 Offline
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We had a similar situation a few years back and I believe we reported it as withdrawn since there wasn't any better option. In your case, I would do incomplete based on your cover letter.

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#2208791 - 03/14/19 08:02 PM Re: Applicant dies - how to report laf0915
anio1424 Offline
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I'd like to re-open this topic. How would you report this loan if the borrower dies and we issued a conditional approval?

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#2208800 - 03/14/19 09:16 PM Re: Applicant dies - how to report laf0915
David Dickinson Offline
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Central City, NE
You can't call it withdrawn because the applicant can't withdrawn the application now.
You could send a denial, but that seems harsh.
You could send a NOI, but that seems ridiculous as they can't respond.

I would probably document the applicant died and call it withdrawn.
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#2208808 - 03/14/19 10:24 PM Re: Applicant dies - how to report laf0915
anio1424 Offline
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David, could it be an approved but not accepted?

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#2208825 - 03/15/19 01:47 PM Re: Applicant dies - how to report anio1424
Adam Witmer Offline
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Originally Posted By anio1424
could it be an approved but not accepted?

I don't see why not, assuming the application meets the criteria for approved but not accepted.
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#2208827 - 03/15/19 02:02 PM Re: Applicant dies - how to report laf0915
RR Joker Offline
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I've had this happen and we had, for all intents and purposes, approved the loan. It was reported ANA.
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#2208868 - 03/15/19 08:25 PM Re: Applicant dies - how to report laf0915
David Dickinson Offline
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Central City, NE
It could be ANA, IF the applicant was fully approved. The OP said they pulled credit and sent early disclosures. I doubt full approval had been achieved at this point. Did you have an appraisal already? If not, you can't verify the loan to value. Therefore, it couldn't be ANA.
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#2241607 - 08/26/20 03:17 PM Re: Applicant dies - how to report laf0915
Red Raiders Offline
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We just had this happen here. Applicant applied for a purchase loan on 8/14 and passed away that evening. We found out about it on 8/17 so we obviously didn't send earlies. For HMDA is Withdrawn still the best action taken to report? By default it seems to be the only one (other than maybe denial) that remotely makes sense.
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#2241610 - 08/26/20 03:25 PM Re: Applicant dies - how to report laf0915
raitchjay Offline
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OK
I see no option that makes any sense except withdrawn, since i don't think anyone with a heart is going to send out an AAN in such a scenario.
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#2241611 - 08/26/20 03:42 PM Re: Applicant dies - how to report laf0915
Red Raiders Offline
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That was my thinking. Thanks
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