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#2275043 - 09/01/22 03:35 PM Notice of Incomplete for ITP?
Joe Offline
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Joined: Aug 2022
Posts: 3
My company has aligned the Reg B application and TRID application definitions. They have also taken the position ITP must be done electronically or in writing, and that a Notice of Incompleteness should not be issued for ITP since it is not something that is required in order to make a credit decision. Naturally, we end up with applicants who haven't provided ITP, but have provided documentation needed for underwriting review, and we approach the end of the 30 day Reg B period.

1. Are there lenders out there who have successfully separated the "application" definitions in TRID and Reg B, and start the timers at different points?
1a. If so, has anyone successfully said that they require ITP in order to even have an "Application" under Reg B?

2. Do others find it acceptable to issue an NOI for just ITP, and then issue another NOI after ITP is received to request verification documents?

I look forward to hearing how others do it!

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Lending Compliance
#2275045 - 09/01/22 04:00 PM Re: Notice of Incomplete for ITP? Joe
raitchjay Online
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Joined: Oct 2009
Posts: 9,088
OK
I don't guess i understand.....how can you make a full credit decision without intent to proceed, unless you're eating the costs of appraisals and title work, etc.?
_________________________
I'm fixin' to fix that.

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#2275080 - 09/01/22 09:06 PM Re: Notice of Incomplete for ITP? raitchjay
Joe Offline
New Poster
Joined: Aug 2022
Posts: 3
Fair question - my company issues conditional approvals, and treats them as "approval" under Reg B. The question has come up that if the customer has provided the required docs to be able to issue the conditional approval, but has NOT provided ITP, our Reg B Timer is still ticking, and we are then required to provide a decision within the 30 days. We have to issue the conditional approval (or deny) because ITP isn't a requirement to issue the approval (and theoretically shouldn't be, since it's not related to the customer's creditworthiness).

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