Regulations B and C and the Date of the Application
Issue/Inquiry
The Bank uses a business loan application that requires certain additional information, such as financial statements, tax returns, and organizational documentation. Once the Bank receives the signed application and required documentation, a “work order” is completed by the loan officer, a credit report is ordered, and the credit underwriting process begins.
Rather than using the date the business loan application was signed, the Bank uses the date of the work order as the date a completed application has been received, which starts the 30-day clock for notification of the action taken on the request. Is such process compliant with the requirements of Regulations B and C?
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