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” information. 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 joined Banker’s Compliance Consulting with twenty years of experience in the banking industry. Her past positions include teller, credit review analyst, assistant financial officer, BSA Officer, Compliance Officer, and Director of Compliance. She has worked for both a small community bank and a large billion-dollar bank.
Deb has Associate Degrees in Business Management and Accounting. She is a graduate of the American Bankers Association National Graduate School of Compliance Management, an honors graduate of Schools of Banking Compliance School, and a graduate of Schools of Banking Advanced School of Banking. Deb’s considerable knowledge and experience make her a valuable member of the Banker’s Compliance Consulting Team. Deb is a Certified Regulatory Compliance Manager (CRCM) and a Certified Anti Money-Laundering Specialist (CAMS).
Deb loves to spend her free time cycling, running, kayaking and weight lifting with her husband. Between them, they have three adult children and six grandchildren. Other interests include anything outdoors and anything she hasn’t done or seen yet!