If a bank establishes what is needed for a complete commercial loan application, including title opinion, appraisal, etc., when would the 30 days for adverse action begin? Would the adverse action notice be required 30 days once the last required item was received, i.e., title opinion, appraisal, etc., if the loan was denied at this point?
On another note, what about commercial applications received, but not all the bank-required information has been received to be considered a completed application? What are the requirements? In this example, how do you determine when or if a notice is required? Are you required to send a notice of incomplete application? If yes, what date do you use to determine when this notice is due and what is the required timing for sending this notice? Is a notice required based on 30 days from when the application (not a completed application) was initially taken?