What is the context of your question and what type of loan are we talking about. Are you talking what triggers disclosures, what contitutes an application for a notice of incompleteness, is this RESPA related? We really need more information. Since an appraisal is under control of the bank, I can't imagine how this plays much of a role.
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Rizzo, if you're talking RESPA application to give disclosures then an application would be viewed as a verification document. RESPA is very explicit that you cannot require those before giving the GFE.
An incomplete application is normally based on information that the applicant provides. You wouldn't send a notice of incomplete application if you where missing an appraisal as that is in the bank's control. You might send them a notice of incompleteness if you contracted for the pre-payment of the appraisal fee and they had not provided it.
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Prior to me, the decision was made to let each division define what they considered a completed application. For one, they chose blah blah blah and the appraisal. I think that's a little far fetched and I'm sure they thought that would buy them more time. I want to push to have a completed application be those items we need from the applicant to move towards a credit decision. Thoughts?
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Prior to me, the decision was made to let each division define what they considered a completed application. For one, they chose blah blah blah and the appraisal. I think that's a little far fetched and I'm sure they thought that would buy them more time. I want to push to have a completed application be those items we need from the applicant to move towards a credit decision. Thoughts?
Reg B defines what an application and completed application are [refer to §202.2(f)]. A bank can't make up their own definition.
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