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#1441352 - 09/10/10 04:00 PM denied or withdrawn
Avanti Offline
100 Club
Joined: Feb 2010
Posts: 139
If an appraiser comes back and says that they have looked up the property and it is going to be more complicated than a standard appraisal, so they are going to charge more. they also say there probably won't be any comparables within the last 2 years.

the borrower is told that the appraisal will cost more and may not qualify, even if they pay more to do it. It may but it is not looking good.

So the borrower doesn't want to pay the extra and withdraws.

Is this a withdrawn or denied?

It probalby would have been denied for collateral, but we really can't say it was because the appraisal was never recieved.

thoughts??

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Lending Compliance
#1441379 - 09/10/10 04:29 PM Re: denied or withdrawn Avanti
kristenw Offline
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Joined: Jan 2008
Posts: 19
Approved but not accepted. If you approved the loan and the customer didn't accept the terms it would be approved but not accepted.

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#1441383 - 09/10/10 04:33 PM Re: denied or withdrawn Avanti
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
You should send an AAN for an incomplete application and report it on the LAR as such. If you had sent them a notice of incompleteness specifying the appraisal and they didn't provide it you would have reported it as closed for incompleteness.

See Conditional Approvals under the Action Taken section:

http://www.ffiec.gov/hmda/faqreg.htm
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1441388 - 09/10/10 04:35 PM Re: denied or withdrawn kristenw
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Originally Posted By: kristenw
Approved but not accepted. If you approved the loan and the customer didn't accept the terms it would be approved but not accepted.


Only if the loan was approved on the terms applied for. Any conditions or change in terms that the applicant did not accept most likely will result in the request being a denial. However, again I will refer you to the FAQs linked above.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1441389 - 09/10/10 04:37 PM Re: denied or withdrawn Dan Persfull
Avanti Offline
100 Club
Joined: Feb 2010
Posts: 139
I should also add. The borrower was told that if the appraisal didn't come back acceptable for the program they originally applied for, it would probably qualify for another program. That program doesn't have as nice a rate since it is for unique properties. The borrowers currently have a better rate. So they walked away.

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#1441400 - 09/10/10 04:47 PM Re: denied or withdrawn Avanti
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Regardless what they were told you had an application for credit. You put a stipulation of an appraisal on the request and the applicant decided not to meet that stipulation. You therefore have an incomplete application and you must take appropriate action under the notification requirements of 202.9 and report on the LAR according the the guidelines for conditional approvals in the FAQs.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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