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#2260855 - 10/06/21 09:33 PM Reg B 30-Day Clock Completed Application
Annie Offline
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Joined: Sep 2018
Posts: 27
Let's say that the creditor considers a mortgage application "complete" for Reg. B when among other things, the appraisal is received. The creditor exercises reasonable diligence in ordering the appraisal as quickly as possible upon receipt of a mortgage application and applicant indicating intent to proceed. Let's say as well that: 1) the appraisal is returned 45 days from the date of application and; 2) during the first 30 days from application a Notice of Incomplete is not sent because the applicant has provided all required documentation that the applicant can provide. At that point, the application is considered "complete" by the creditor and the 30-day clock for evaluating and making a credit decision starts. Does this scenario comply with Reg. B or is the creditor out of compliance because no notification was made within the first 30 days?

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#2260865 - 10/07/21 11:22 AM Re: Reg B 30-Day Clock Completed Application Annie
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,294
Galveston, TX
The application is not complete without the appraisal, it is just you no longer need information from the applicant. This is where file notes are important. A notice of incompleteness is required when you need information from the applicant.
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#2260869 - 10/07/21 12:42 PM Re: Reg B 30-Day Clock Completed Application Annie
Rocky P Offline
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Joined: Jun 2003
Posts: 7,240
Florida
Think of the reg as a “rolling” 30 days. The creditor has 30 days from when they receive a completed application, that is, all the information they need to make a decision. If a credit report comes back bad, the bank has 30 days to let the applicant know from that time. If the credit is OK, it goes to the next steps, verify income, assets, property value. If the first receipt a week later is income, the creditor has 30 days from that point. Etc., etc., etc.

Like Randy mentioned about the appraisal, the caveat is that ordering all documents should be as expedient as possible. Read the definition of “completed application “ in 1002.2.
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