For example, the creditor should request information from third parties, such as a credit report, promptly after receiving the application.
If additional information is needed from the applicant, such as an address or a telephone number to verify employment, the creditor should contact the applicant promptly.
Notification in accordance with § 1002.9 of the regulation generally is required, however, if the creditor's action is based on a past delinquency or default on the account. When an applicant applies for credit and the creditor does not offer the credit terms requested by the applicant (for example, the interest rate, length of maturity, collateral, or amount of downpayment), a denial of the application for that reason is adverse action (unless the creditor makes a counteroffer that is accepted by the applicant) and the applicant is entitled to notification under § 1002.9.
But if the creditor's program does not provide for giving written commitments, requests for preapprovals are treated as prequalification requests for purposes of the regulation. Under the same facts as above, the financial institution evaluates the person's creditworthiness and determines that she does not qualify for a preapproval. The regulation defines a completed application in terms that give a creditor the latitude to establish its own information requirements.
Nevertheless, the creditor must act with reasonable diligence to collect information needed to complete the application.
(But see comment 9(a)(1)-3, which discusses the creditor's option to deny an application on the basis of incompleteness.) 2(g) The test for deciding whether a transaction qualifies as business credit is one of primary purpose.
For example, an open-end credit account used for both personal and business purposes is not business credit unless the primary purpose of the account is business-related.
References are to sections of the regulation or the Equal Credit Opportunity Act (15 U. This commentary is the means by which the Bureau of Consumer Financial Protection issues official interpretations of Regulation B.