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During the webinar this morning you mentioned Alliance Lending allowed employees during initial calls to treat the interactions as applications for credit by advising the consumer that they were “ineligible” or “not qualified” for a mortgage loan without issuing an adverse action notice. Can you elaborate when you have to send an adverse action notice. We had a incident before where the customer up front told the lender they had filed for bankruptcy last year and we don’t do loans for bankruptcies until they have been discharged for 2 years. An application was never filled out and credit was not pulled but based on the webinar it sounds like we still should have sent an adverse action notice. Can you point me in the right direction. Thank you!
Annmichele,
You should already have our Providing Accurate and Timely Adverse Action Notices training manual in your possession. If you prefer, it can be downloaded here https://jackscompliance.s3.amazonaws.com/woocommerce_uploads/2020/12/CRLW-Providing-Accurate-and-Timely-Adverse-Action-Notices-12.01.20-bp1ra4.pdf
You’ll find the information you need in the last block on page 12 and the first block on page 13.
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