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#2262618 - 11/17/21 10:19 PM Incomplete Application - AAN
complyorelse Offline
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We had an application (residential) where the applicant never signed the disclosures so we didn't have intent to proceed. The application likely would have been approved because we did have the income information, the equity in the home was there (online appraisal ordered due to very small loan amount), but we didn't hear back from them. An AAN was generated for Incomplete Application.

My understanding is that we should not check the FCRA box "we obtained your credit score..." and provide the score information for an incomplete application because really no final decision is made with an incomplete application. I've seen threads that by doing so the applicant is given rights they aren't necessarily entitled to.

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#2262625 - 11/18/21 06:34 AM Re: Incomplete Application - AAN complyorelse
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,922
Galveston, TX
Denial for an incomplete application has nothing to do with a credit report unless you were lacking information because of something that was in their report, so I agree, you do not include that on the AAN.

You stated: "We had an application (residential) where the applicant never signed the disclosures so we didn't have intent to proceed. "

Those two actions are not really related. The LE is not required to be signed unless you make it a requirement to do so. Even with an intent to proceed, how would this change the situation?
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#2262635 - 11/18/21 01:54 PM Re: Incomplete Application - AAN complyorelse
complyorelse Offline
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I added the fact we didn't have any signed disclosures because we did order the appraisal (not a practice I think is wise); wanting to give as many facts as possible so all context is known.

We did not hear back from the applicant. The application needed to be closed out. We do require signed disclosures. Since we did not get them back, it seems appropriate to deny for incompleteness.

Does that not sound correct?

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#2262647 - 11/18/21 03:51 PM Re: Incomplete Application - AAN complyorelse
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,922
Galveston, TX
What I was saying is whether or not someone returned signed disclosures to you has nothing to do with whether or not they have given you an intent proceed. They could give a verbal intent to proceed and never return the signed disclosures. Acknowledging receipt of the early disclosures is not an intent to proceed. Those are two separate actions and are not related to whether or not a credit report played any part in denying the application because of any information contained in a credit report.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2262666 - 11/18/21 06:04 PM Re: Incomplete Application - AAN complyorelse
complyorelse Offline
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Joined: Nov 2007
Posts: 441
U.S.
Thank you.

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