In a scenario where the appraised value came in low, would an appraisal be considered as 3rd party information?
If you deny an application because the applicant cannot get clear title on the property what reason would you use on the denial notice (would you create an “Other” reason)?
If you do a preapproval/prequalification where you have five pieces of information (not the property location) and the customer is approved for an amount but the customer never comes back to the bank. What is the proper procedure in this situation?
In regards to the check box options on an adverse action notice, as a commercial lender, I would like to add “Length of time in business is too short” as we do deny credit to many newly established companies (per our credit policy), so my question is this: Can I create my own reason(s) or are there a specific set of reasons that I need to adhere to? Where does ‘length of time in business too short’ (or verbiage to that effect) fit on an adverse action notice?
If you use a vendor that provides scores from all 3 bureaus and you only use the score/reasons from one bureau for the denial, do you use that specific bureau's name and address or the actual vendor that supplied the report for your adverse action?
Are we allowed to include the Negative Information Disclosure language in the promissory Note form for all applicable loans?
We currently provide a separate one page document with just the Negative Information Disclosure language on it for the customers to sign. I was hoping to eliminate one document by including this in the Note.
Should we have one or more employees that are designated to handle all customer complaints? Should all complaints be referred to them no matter who initially receives the complaint?
How much flexibility do we have in defining “an application”?
We are offering loans via a mobile app. Can we accept scans of IDs as that is a good way to help verify we are engaged with our customer, by having them send us a picture of their ID using a smartphone.
What is the proper way to respond to an inquiry about a loan?