In order the application to be treated as withdrawn, it has to be expressly withdrawn by the applicant.
OSC 202.9 Comment 2. Expressly withdrawn applications. When an applicant expressly withdraws a credit application, the creditor is not required to comply with the notification requirements under ยง 202.9.
Losing touch with the applicant does not equal withdrawal. I would recommend that you move to using the notice of incompleteness.
You have two problems here - the applications should have be treated as denied for incompleteness and you have also violated the 30 day time frame in which to make a decision after receipt of the application.
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