ECOA

(Under ECOA) After we have a credit-only approval for an application, how long can the application remain active in our pipeline? For example, if we submit a credit-only file to an underwriter (without a property) and the file is conditionally approved (based on credit qualification only), and the applicant is looking for a home or waiting for a new construction to be finished, how long can we hold that app in our pipeline before getting scrutinized by an examiner (we are under the FRB)? I’ve seen a range from 45 to 90 days – but obviously, we want as big of a window as possible before we have to action the loan … especially if the borrower is simply waiting for their property to be completed.