Answer:
Randy Carey: Should the application files contain enough information to prove that the application was either approved but not accepted or withdrawn before a credit decision was made? Yes.
Answer:
John Burnett: If there is no copy of correspondence in the file to document that the application was approved, but not accepted, there should be an annotation -- perhaps on the file copy of the letter to the applicant approving the application -- that the applicant called or texted or otherwise communicated that non-acceptance. Or, if the approval letter/email included a "Please let us know by [DATE] whether you wish to accept these terms," request, and the applicant never responded, there should be an annotation on the retained copy of the bank's correspondence to indicate there was no response from the applicant by [DATE].
If the applicant contacted the bank to withdraw the application before the bank had made a credit decision, a simple annotation in the file would suffice.
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