Reg B, specifically the notice of incompleteness letter is a current project we are working on to become more efficient. I would like some input on how some of you handle sending the disclosure. It's currently more of a manual process for us.

Does anyone send out the NOI letter with initial disclosures or are you waiting more towards the 30 day mark?

When does your 30 day clock start on pre-qualifications?

How do you handle the permanent phase of two-phase construction lending?

Thanks!

1. Our cover letter with the LE informs the applicant if they don't provide the intent to proceed within a stated time then we will consider the application incomplete and will take no further action. Once we get into UW and there is information we are waiting on from the applicant we will send the NOI within 30 days of receiving the application advising the applicant what information we need and when we need it by.

2. When we get a complete application or take adverse action.

3. We process the construction loan request and the permanent loan request at the same time. If the permanent loan request does not get an accept from LPA then we will not process the construction loan.

1. What do you consider starting the clock for the 30 window to send the NOI?

2. What do you consider a complete application? Our examiners are telling us the 30 clock starts from the date we pull credit for prequals.

You can define an application and complete application for your institution. A prequalification is not an application (unless you decision it). Pulling credit on something that is not an application is something that some people do not like though. You can find plenty of posts debating it on BOL.

3. When an inquiry or prequalification request becomes an application. A creditor is encouraged to provide consumers with information about loan terms. However, if in giving information to the consumer the creditor also evaluates information about the consumer, decides to decline the request, and communicates this to the consumer, the creditor has treated the inquiry or prequalification request as an application and must then comply with the notification requirements under § 1002.9. Whether the inquiry or prequalification request becomes an application depends on how the creditor responds to the consumer, not on what the consumer says or asks. (See comment 9-5 for further discussion of prequalification requests; see comment 2(f)-5 for a discussion of preapproval requests.)