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Incomplete Application - Adverse Action & Denial Letter

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Question: 
A client submits a credit line application, but forgets to sign it. The client is notified via phone that the application is incomplete and a signature is needed. The client says he will come back the next day to sign the application. In the meantime, to expedite the process, the banker pulls the client's credit report. Once the credit report is pulled, it is seen that the decision will be to deny the credit due to the clients’ credit score and history. Unfortunately, the client never comes back to the bank to sign the application. Is the adverse action categorized as incomplete, since the client never signed the application, or is the application considered a denial, since credit was pulled and a decision made regardless of the application not being signed? Is a denial letter required to be send to the client?
Answer: 

The bank moved forward on the application, regardless of how your policy defines an application. The bank pulled the credit report and reached a decision, and must now handle the application based on that decision. Adverse action is triggered. If your applicant is an individual (a consumer), written notice is required.

First published on BankersOnline.com 4/19/10

First published on 04/19/2010

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