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A file review found that an application that the officer considered “withdrawn” should actually have had an Adverse Action Notice sent 3 months ago. The loan officer has been trained on the error. In these situations, would you advise still mailing the Adverse Action Notice to the customer months later?
The violation of the required time frame for delivery has occurred and cannot be corrected, but the requirement to provide it still remains. Sending the AAN now will inform the customer of the reason for the adverse action. It may also prevent further digging by examiners to see you have taken all necessary actions to correct and prevent this from reoccurring.
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