Geneva Financial Adverse Action Guide
When you need to adverse a file, please email the disclosure desk (email@example.com) with the reason for the adverse action from one of the 4 options below and a brief explanation of what has occurred. In addition you MUST complete the borrowers demographic information on page 3 of the 1003 or the HMDA screen. Please note: You cannot mark the “I do not wish to provide” or “information was not provided” boxes. If the borrower is not willing to tell you their ethnicity or sex, a determination must be made by visual observation or by the borrower’s surname (see CFPB snip from the new HMDA rule below).
You must be specific and choose from one of the 4 reasons listed below which is required by ECOA and HMDA:
1. Approved but not Accepted Applications: Applications that are “cancelled” after they have been fully Approved with no outstanding income/credit conditions needed from the applicant (e.g., applicant decides not to go through with the transaction, rescinds, or goes with another lender).
2. Application Denied by Financial Institution: Most other applications that “cancel” subsequent to underwriting with outstanding credit or income conditions are to be Denied by Financial Institution.
a. An application that “cancels” after underwriting because the applicant cannot or will not provide the required conditions is a denial.
b. An application may be denied because it is incomplete.
c. All applications suspended by the Underwriter must be “Denied by Financial Institution.”
3. Withdrawn Applications: If applicants change their minds and decides not to go through with the transaction before it is underwritten, choose Withdrawn. An application cannot be withdrawn after it has been underwritten.
4. File Closed for Incompleteness:
a. An approved application, subject to underwriting or creditworthiness conditions and a notice of incomplete application was sent to the applicant but the applicant failed to respond within the specified time.
b. Applicant had not satisfied all underwriting or creditworthiness conditions, Financial Institution sent written notice of incompleteness and the applicant did not respond to the request for additional information within the time period specified on the notice.