Originally posted by an anonymous author with the title AVP Regulatory Compliance and Legal on 15 Jul 2019 to CBANC FI Professionals Community.
Hello! I am wondering how everyone else handles old/expired indirect applications. We are trying to keep our lending queues within our LOS clean and up to date with current applications, making sure that once the application has expired that we are sending out an adverse action to let the member know that he/she would need to reapply as the credit has expired. We started doing this on the indirect side last month, by declining them within our system it alerted the dealerships of new activity through Dealer track/Route One and they are less than thrilled about all the RED marks showing on their side. What do you guys do to remove the expired applications? Do you send out an Adverse Action? Do you let it age out of the system? Do you just “cancel” it, and make it go away? Any incite on this is appreciated!
Does anyone have an editable Notice of the Right to Request Reasons For Credit Denial & ECOA notice for Commercial purpose Denials?
I have revised a tool I may have provided a long time ago - it is designed to use as you go through an adverse action file, with one section focused just on the notice itself. Now includes MLA and better flow (IMHO). Might need a little tweaking for your bank's process. Hope you find this helpful - I also use this to train others on what to look for in the file for compliance purposes.
A chart of reasons for adverse action and an explanation of each.
Would someone be willing to share the form or notification they use to notify a customer they are restricting their Overdraft Protection account?
Would you also be willing to share under what events you might terminate or restrict a plan (borrower moved out of market area, no deposit to account tied to the ODP in 'xx' number of days, etc.)?
This is a simple denial form for deposit accounts based on information contained on a credit report (specifically Equifax but this could be changed).