Situation: A lender gathers publicly available information to assess a public request for a loan quote by a city municipal. The Bank has not contacted or been contacted by anyone from the city municipal (verbal or written). After an internal review of the publicly available information, the Bank determined not to extend a quote.
1) Since the Bank does not have an application; an adverse action notice is not needed?
2) Does the Bank need to log this situation?
3) what should be done with the publicly available items the lender collected?
My initial thoughts are:
1) There is no application or even an inquiry. Was the decision communicated to the municipality?
2) I am not aware of any requirement to “log” this situation.
3) The public information is not required to be retained, since there is no application. There are no privacy concerns since it is public data.