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#1844408 - 08/21/13 02:14 PM Regulation B - 30 day notice
BNH Offline
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BNH
Joined: Feb 2013
Posts: 108
For commercial loans, is a 30 day notice only needed if the approval date is 30+ days from the application date? Or is it needed to document the file if the loan is not closed within 30 days. Being used as documentation that the customer has been notified within 30 days? Then if the application date and notification of approval or denial is more than 30 days the lender needs to supply a reason.

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Lending Compliance
#1844413 - 08/21/13 02:23 PM Re: Regulation B - 30 day notice BNH
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
If annual revenue is $1 million or less the bank follows the standard 30 days. If revenue is >$1 million, the rule is a reasonable period of time.

Using 30 days as the example, the bank has 30 days from initial application to approve, deny or notify of incomplete application (stating what is needed). The Reg B clock then stops.

Once the requested information is provided, the bank has 30 days to make a decision and notify of appproval or denial.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1844422 - 08/21/13 02:32 PM Re: Regulation B - 30 day notice BNH
BNH Offline
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BNH
Joined: Feb 2013
Posts: 108
So if a loan is approved/declined within 30 days then we do not need a Reg B 30 day notice in the file?

We were originally going by the application date and closing date. If it was more than 30 days then we would have the lender fill out the form so we had documentation that the customer was actually notified of approval or denial.

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#1844442 - 08/21/13 03:05 PM Re: Regulation B - 30 day notice BNH
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
That will be purely a policy decision for your bank, as it appears by a "Reg B 30 day notice in the file" you mean an internal form.

If the customer was advised of approval within 30 days, but closing took place beyond 30 days (entirely likely) there is no Reg B issue.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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