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When Is This An Application

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Question: 
If a lender takes only basic inquiry information so it can review a credit bureau report, and later takes an application for a mortgage loan, is the date of application the date we pulled the credit report, or the date we got the complete application?
Answer: 

For the purposes of Regulation B, the application is complete when you have the information you require to make a decision on the application. This is defined under 202.2(f).

Under FCRA, you accessed the credit report earlier for an allowable purpose.

The date you actually have your completed application, traditionally a Form 1003 for mortgages, is the date of application, again for purposes of Regulation B. Your loan policy and procedures manual should define which documentation and other material you need to complete the application. The list might include, in addition to the application, copies of pay stubs, a credit report, verification of deposit, etc.

First published on BankersOnline.com 08/16/04

First published on 08/16/2004

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