Date: June 28, 2018
Compliance Memo C2018-04: Notice of Incomplete (NOI)
This memo will clarify the intent and purpose of the Notice of Incomplete (NOI) as it relates to Loan Status and Regulation B and ECHO requirements.
Per TRID’s guidance regarding a complete application (which includes applicant(s) name, address, social security #, loan amount, and estimated or appraised value), we are required to provide the applicant(s) with a credit decision within 30 days of the application date.
1.) If we have the documentation required to submit the loan to underwriting, the loan must be submitted and a credit decision made. (Credit decisions include Conditionally Approved Loans.)
Underwriting requires the following documentation in order to issue a “credit” decision:
- Signed Application
- Credit Report
- Credit Authorization
- Income Documentation
- Asset Documentation
2) If we do not have all documentation required for loan submission, we can then issue a Notice of Incomplete(NOI) which will advise applicant(s) of the specific outstanding documentation required to continue the processing of their loan application. The NOI will also mandate a timeframe in which said documentation must be received. Issuing the NOI fulfills our requirements according to Regulation B and ECHO and extends the loan to remain in an active status. It does NOT close out the loan.
When loan age reaches 25-30 days, Gold Star’s Loan Status Department will send an email alerting the Loan Officer and Loan Processor of the need to have the loan dispositioned, and prompt them to select one of the following options:
- Applicant(s) withdraw;
- Loan will be submitted to Underwriting or,
- Issue NOI with required documentation and timeframe.
NOTE: If after having issued a NOI, the applicant(s) does not provide the required documentation within the specified timeframe, the loan may be “closed for incompleteness” at that time.
Appraisal, VOE, Purchase Agreement, or any other documentation not listed above are not required to submit loan to Underwriting for a credit decision and are not acceptable reasons to issue a NOI.
If you have any questions, please reach out to Loan Status at: firstname.lastname@example.org