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#1997189 - 02/20/15 02:06 PM Adverse Action on a Preapproval - ANA
BHepting534 Offline
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BHepting534
Joined: Dec 2014
Posts: 7
Pittsburgh, PA
Is there a regulatory requirement that would require our bank to issue any kind of adverse action notice or other disclosure to a borrower who has not accepted our approval of a preapproval? Our bank does have a preapproval program, and we do choose to report Preapproval ANAs. Between HMDA, Reg B, and RESPA, I get pretty confused on what communication is required for each.

Thanks!

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Fair Lending
#1997224 - 02/20/15 03:01 PM Re: Adverse Action on a Preapproval - ANA BHepting534
Rocky P Online
Power Poster
Joined: Jun 2003
Posts: 7,659
Florida
For
HMDA, it would be
Code 8—Preapproval request approved but not accepted (optional reporting)

ECOA, the bank approved it, and it would not be a decline. If the approval was communicated, nothing else needs to be done.

RESPA, nothing - no property.
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Integrity. With it, nothing else matters. Without it, nothing else matters.

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