Hello. Hoping to get some feedback on a situation at my bank. Our telephone banking center has gotten 10-12 calls in the past two weeks from an apparently inebriated gentleman applying for a loan. Due to his state, he claims not to remember having previously applied for a loan with us. To this point they have been taking the application as if it were the first one he had made. Is there a way we can refuse to accept an application from this gentleman without running afoul of the lending regs? We would not be declining to accept the application on a prohibited basis, we would be doing so because he had been denied credit recently. Do we need to send out 12 AA letters in 14 days? Does anyone out there want to give me the number for their phone banking center so I can refer this guy there? ;-)

"apparently" inebriated. careful. if his written app does not meet your credit guidelines, a declination is perfectly proper. should he be deemed, credit worthy on his merits, you cannot decline based on a supposition.

The credit application has been declined multiple times on its merit (or lack thereof). The fact that the customer seemed intoxicated was mentioned only to explain why he did not remember previously applying.

The question raised in the post is what steps have to be taken when the customer applies an additional 9-11 times in the two weeks after he was originally declined (do we need to pull credit again, run through underwriting department).

We had a very similar situation. I finally asked our examiner how we should handle this. He said that we could ask the individual if any circumstances or information contained on the most recent loan application dated xx/xx/xx had changed which might change the underwriting decision. If not, he said we did not have to take another application. If the applicant says yes, you have to take the application.