A customer presents a paper application at a branch location. The branch sends the application to a central location for underwriting and processing but the central location sends the application back to the branch and request that they obtain additional information from the customer before they begin processing the application.

Is this an incomplete application requiring the bank to handle this as such under Regulation B and send the customer an incomplete letter requesting the additional information or sending a denial letter for incompleteness within 30 days of receipt of the application in the branch? Or, since the processing center sent the application back to the branch requesting them to reach out to the customer for the additional information so that the application can be processed, therefore the bank has not received the application and does not have to follow the incomplete process of complying with Regulation B?

I'm thinking an incomplete letter or an adverse action letter may be required as the branch received the application. If the processing center request the branch to assist with collecting information, that's permissible. But, if the information requested is not received within 30 days of receipt of the application in the branch, then the bank would be required to comply with sending an incomplete letter or an adverse action letter denying the request due to being incomplete. Am I right?

You have an incomplete application as of the date the applicant presented it to the branch. Your Reg. B requirements started on that date.

Thanks Dan! That's my take on it too . Receipt at the branch is receipt at the bank and Regulation B timing starts.