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#2273167 - 07/21/22 02:03 AM Adverse action
theloanbug Offline
Platinum Poster
Joined: Sep 2005
Posts: 720
Customer withdraws after 30 days for real estate loan. How do you handle this situation? Changed mind. Do you do an adverse action or not?

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Lending Compliance
#2273170 - 07/21/22 12:42 PM Re: Adverse action theloanbug
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,643
Galveston, TX
I am confused as to why the timing of the withdrawal would impact how you handle it?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2273195 - 07/21/22 02:17 PM Re: Adverse action theloanbug
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,844
Bloomington, IN
An applicant withdrawing the loan request before an adverse credit decision is made is not adverse action and would not required an AAN.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2273196 - 07/21/22 02:20 PM Re: Adverse action theloanbug
Inherent_Risk Offline
Gold Star
Joined: Jan 2017
Posts: 374
Did you send an NOI? Doesn't sound like there was an adverse action, so not sure why you would send an AAN.

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#2273430 - 07/27/22 02:07 AM Re: Adverse action Inherent_Risk
theloanbug Offline
Platinum Poster
Joined: Sep 2005
Posts: 720
If customer withdraws no adverse action needed, correct? Do you document file and file it way?

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#2273431 - 07/27/22 11:07 AM Re: Adverse action theloanbug
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,643
Galveston, TX
Yes, you maintain documentation as to the date and time and how the customer communicated the withdrawal and maintain the application file for 25 months.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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