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#2245317 - 11/09/20 08:21 PM Credit Decision - Without Intent To Proceed
Shih_Tzu_Lvr Offline
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Joined: Nov 2011
Posts: 86
Can you provide a credit decision (Notice Of Incomplete, Approval or Denial) prior to receiving intent to proceed from the applicant?

Please note this is after the 3 day period and a Loan Estimate / Disclosures have been released to the applicant.


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Lending Compliance
#2245320 - 11/09/20 08:34 PM Re: Credit Decision - Without Intent To Proceed Shih_Tzu_Lvr
raitchjay Online
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Joined: Oct 2009
Posts: 9,088
OK
Well, i don't see how an approval would be possible, since you wouldn't have ordered title work and the appraisal prior to receiving the ITP. But a denial for incomplete application or closed for incompleteness (if you sent the notice)? Sure, assuming you mean the 10 "good through" days have passed.
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#2245353 - 11/10/20 03:59 PM Re: Credit Decision - Without Intent To Proceed Shih_Tzu_Lvr
John Burnett Offline
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John Burnett
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Cape Cod
You could decide not to make the loan after three days but before the ten-day deadline based on a credit report. And you could provide the applicant with an adverse action notice before the applicant has decided to proceed with the application.
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#2245377 - 11/10/20 05:48 PM Re: Credit Decision - Without Intent To Proceed Shih_Tzu_Lvr
raitchjay Online
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Joined: Oct 2009
Posts: 9,088
OK
John...my thought on that was that at a minimum, it's sort of an industry standard to pull the credit report before issuing the LE. You agree?
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#2245378 - 11/10/20 05:52 PM Re: Credit Decision - Without Intent To Proceed Shih_Tzu_Lvr
rlcarey Online
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rlcarey
Joined: Jul 2001
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Galveston, TX
Loan officer actions and industry standards - I think that represents an oxymoron.
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