Notice of Incomplete App

Posted By: mdog76

Notice of Incomplete App - 09/08/17 05:01 PM

Do we need to send anything like a notice of incomplete app on a commercial loan? From what I know, the loan has been pre-approved just waiting on property address from customer.

Thanks.
Posted By: David Dickinson

Re: Notice of Incomplete App - 09/08/17 07:38 PM

If you have pre approved them, then the ball is in their court. Reg B says you have to let them know. If you told them "We can make you a loan up to $x. Let us know when you find a house" then you have met Reg B requirements. If you want to put a time constraint on them, issue a NOI with a "drop dead" date. If they don't respond by then, you're done.

Either way you look at it, there's no regulatory requirement on you. You're waiting on them.
Posted By: Rocky P

Re: Notice of Incomplete App - 09/11/17 06:47 PM

mdog, agree with David.
One other reason to give them a date is that the credit docs usually expire. If they go on too far, the loan may have to be re-written