Review section 202.9(a)(1)(i). It appears you have a completed application, and the delay is strictly not a borrower problem. You should have notified the applicant of your decision to approve the loan within the 30-day period. Your notice could describe the delay in moving forward.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8