Technically the loan officer is correct for Reg. B purposes.
Expressly withdrawn applications. When an applicant expressly withdraws a credit application, the creditor is not required to comply with the notification requirements under §202.9. (The creditor must comply, however, with the record retention requirements of the regulation. See §202.12(b)(3).)
However, once the loan decision has been documented in the file; and the applicant withdraws the application on or after the date of the decision, how can the loan officer prove/document that the applicant did not withdraw the application because the loan officer verbally denied the request?
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The opinions expressed are mine and they are not to be taken as legal advice.