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What’s an app for Reg B/1

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Question: 
We had the 6 points of information for an application but lost track of the request and took too long to deny it as we were awaiting additional income information from the applicant. What can we do now?
Answer: 

Don’t confuse Reg B and Reg Z’s TRID rules. Without more information, I’ll narrow the answer to Reg B. In Reg B the bank defines what is an application and that can be very different than the TRID rules. If under Reg B the bank requires this additional information in order to have a complete application, then the bank doesn’t have that yet, this may be an incomplete application. (That won’t help you on TRID disclosures, however.)

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Learn more about Andy Zavoina’s webinar A-Z of Reg B

First published on 07/19/2020

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