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#2191574 - 09/04/18 04:55 PM Declied Loan: change in Income & DTI post DECISION
Compliance Buzz Offline
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Joined: Feb 2002
Posts: 319
NJ
We have a situation where a loan was declined due to deficient income and DTI. The Bank's decision to deny the loan was made on a Monday, decline letter was to be sent on Tuesday, but on before the adverse action notice was sent, the borrower submitted additional proof in income. The income was recalculated, which resulted in a different income and DTI amount, however, the income was not enough to change the credit decision, therefore the original decline letter from a few days before was sent to the applicants.

ORIGINAL decision date of 4/9/18 with income and DTI on that date being 75k and 108% respectively. AFTER the additional income was considered and evaluated, the income and DTI became 98k and 64% respectively, BUT was still not enough to change the original decision and decline reasons, therefore the 4/9 decline was sent to the borrower as nothing with the decline had changed.

We are reporting the decision date as 4/9/18, as the new information did not change the original decision. What w e're struggling with is: what do we report for income and DTI: the data used on the decision date (4/9) or the data used a few days later, which was recalculated and supported the original decline?
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#2191576 - 09/04/18 05:28 PM Re: Declied Loan: change in Income & DTI post DECISION Compliance Buzz
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
That's what you used, that's what I'd report. You had no knowledge of the additional income on 4/9. However, you need to consider if you re-opened the file [sounds to me like you did]...and if so, your denial date and newest info should be reported based on that more recent date.
Last edited by RR Joker; 09/04/18 05:29 PM.
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