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#2243195 - 09/28/20 04:31 PM denial or withdrawal - loss of job
complyorelse Offline
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Joined: Nov 2007
Posts: 442
U.S.
If borrower loses job during the application process, informs the lender of this fact and states they would like to withdraw the loan, do we have a denial or a withdrawal? We had not decisioned the application yet. It seems like a withdrawal since the borrower expressly stated their wish to withdraw before decisioning, but we would have had to deny the loan since we would not have been able to verify employment. Thoughts?

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Lending Compliance
#2243198 - 09/28/20 04:40 PM Re: denial or withdrawal - loss of job complyorelse
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,622
If the borrower truly initiated contact to the bank and withdrew, I would call it a withdrawn loan for Reg B purposes. However, I have seen instances where a loan officer "steered" a customer to withdraw due to this type of information. If that was the case, it would be a denial. Just make sure you document your file clearly as to what actually happened.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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#2243199 - 09/28/20 04:44 PM Re: denial or withdrawal - loss of job complyorelse
complyorelse Offline
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Joined: Nov 2007
Posts: 442
U.S.
Thank you for the quick response. Most helpful!

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