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#2248844 - 02/08/21 05:20 PM HMDA purpose
MusicCityCRCM Offline
100 Club
Joined: Apr 2015
Posts: 228
If a customer completes an app, but we never hear from the customer again after providing the LE and do not receive an intent to proceed to move forward with verification of info, we would decline the transaction, but I cannot decide what the decline reason should be. I've reviewed some transactions where our lenders are declining it as an incomplete application and I do not feel this is accurate.

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#2248846 - 02/08/21 05:31 PM Re: HMDA purpose MusicCityCRCM
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,658
You can decline it as an incomplete application. That is fine.

From the commentary:
3. Incomplete application—denial for incompleteness. When an application is incomplete regarding information that the applicant can provide and the creditor lacks sufficient data for a credit decision, the creditor may deny the application giving as the reason for denial that the application is incomplete. The creditor has the option, alternatively, of providing a notice of incompleteness under §1002.9(c).

4. Incomplete application—denial for reasons other than incompleteness. When an application is missing information but provides sufficient data for a credit decision, the creditor may evaluate the application, make its credit decision, and notify the applicant accordingly. If credit is denied, the applicant must be given the specific reasons for the credit denial (or notice of the right to receive the reasons); in this instance missing information or “incomplete application” cannot be given as the reason for the denial.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2248847 - 02/08/21 05:35 PM Re: HMDA purpose MusicCityCRCM
MusicCityCRCM Offline
100 Club
Joined: Apr 2015
Posts: 228
Ok good to know, thanks!

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