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#2269429 - 04/20/22 08:59 PM ECOA, Notifications Approved Loans to Consumers
IGaev Offline
Member
Joined: Dec 2016
Posts: 55
We're transitioning to a new loan origination system and plan to change branch procedures to allow for verbal notification of loan approvals for consumer loan applications. Under ECOA, it states that approvals can be "express" or by implication. We understand express to mean that "no" written notification is required. Is that an accurate interpretation? Please note that we would indicate the date/time the consumer was contacted in the new loan origination system as a way to ensure that notification was provided timely. Thank you and we welcome your thoughts.

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Fair Lending
#2269433 - 04/20/22 09:22 PM Re: ECOA, Notifications Approved Loans to Consumers IGaev
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
A good example of "implied" approval is a phone call or email to schedule a date for signing the loan documents. You do not need to put pen to paper, or fingers to the keyboard to convey approval to the applicant.
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