Don’t Let TRID Trip You Up on Regulation B Adverse Action Requirements

Under the Equal Credit Opportunity Act (Regulation B,) a completed application occurs when you have enough information to make a decision. The information doesn’t necessarily have to be “verified” Deb11information. Obtaining verifications is part of the underwriting process. If you tell someone “no”, you owe them an adverse action notice – whether you had a completed application or not. If you tell an applicant you need verification items, such as an appraisal, for their application to be complete, you are in violation of both Regulation B and TRID.

Deb Irving

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