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#927748 - 03/21/08 02:22 PM Reg B timing/notif - title issue
Anonymous
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Not sure what to do with this loan. Customer applied for purchase and it's past 30 days since applicant applied. Attorneys at the title company are trying to work on some title issues. How do we comply with the Reg B notification timing? It's not withdrawn, it's not denied, it's not really incomplete although that's probably the closest description. Loan officer just wants to keep it in pending, but I think we have to do something in writing.

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#927929 - 03/21/08 04:14 PM Re: Reg B timing/notif - title issue Anonymous
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In my opinion, it seems like the status of this loan IS pending. This is an underwriting issue and NOT a credit issue. The requirement to notify of any adverse action deals with credit. If you had info that his/her credit was less than perfect and unacceptable by your institution's guidelines, you would be required to send the adverse action notice within the designated timeframe.

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#928135 - 03/21/08 06:31 PM Re: Reg B timing/notif - title issue Dallas Fan
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
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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#928202 - 03/21/08 07:17 PM Re: Reg B timing/notif - title issue John Burnett
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Yes, John is correct, a pre-approval letter with any contingencies would be in order. Sometimes I miss the Forest through the trees! TGIF

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#928326 - 03/21/08 08:22 PM Re: Reg B timing/notif - title issue Dallas Fan
Anonymous
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Commitment letter with typical conditions was issued prior to location of prop. and they were preapproved for $140,000 (amount on appl). Found property for $130,000. Told verbally they were approved pending appraisal. Appraisal not ordered yet due to the attorneys still trying to work out these title issues.

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