Notice of Incompleteness (NOI) is a letter from the lender to the loan applicant to request the applicant to provide documentation or information that is needed by the lender to make a credit decision. The purpose of NOI is to inform the applicant of the information or documentation that is needed to complete application.
NOI is required as per the notification requirements of Regulation B as specified in Section 1002.9.
NOI contains the following information:
Items 1 to 3 are required by Regulation B.
You should respond to the NOI by providing the information requested by the lender. Contact the lender promptly, if you are not clear on what is required or if you need additional time to collect the information and respond. Remember, you need to respond before the due date listed in the NOI, otherwise your loan application may get declined.
You have two different approaches on how you handle incomplete applications. Within 30 days from date of application, you can either deny the application citing incompleteness as a denial reason, or send a Notice of Incompleteness. Whichever approach you take, it is important that you consistently take the same approach for all incomplete applications. Your Reg B/ECOA policy should also specify how you handle incomplete applications.
There are two timing requirements with the NOI:
NOI should be sent in writing for residential loan applications. If a written notice of incompleteness has been sent to the applicant, then you have no further obligation if the applicant fails to respond within the designated time period. You may then cancel the loan application.
When there are more than one loan applicants, you should send the NOI to the primary applicant, if readily identifiable. If a primary applicant cannot be identified then send the NOI to any loan applicant.
Maintain the NOI, along with other application documents, for a period of 25 months after the date you have notified an applicant of incompleteness. You may have to retain the records for a longer time period under investigation or is subject to enforcement proceeding. The recordkeeping requirements are specified in § 1002.12 of Regulation B.
Updated: Nov 04, 2013