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ECOA Timing Traps: Getting the Notice of Incompleteness (NOI) and Timelines Right

Course Description

ECOA has strict timelines—and mistakes here are one of the most common exam findings. This session takes a closer look at timing rules, including the proper use of the Notice of Incompleteness (NOI), how to stop the clock, and how to document timelines for withdrawn, incomplete, and denied applications. We’ll also walk through recent examiner trends and how to prepare for them.

Agenda

  • Overview of ECOA timelines: what’s required, and what examiners expect

  • When and how to issue a valid Notice of Incompleteness

  • Understanding application date definitions and their impact on timing

  • How to document and explain timing decisions for complex files

  • Common examiner findings related to ECOA timelines and how to avoid them

  • ECOA timelines and HMDA alignment: avoiding mismatches

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September 10

Audit Readiness or Ready When They Are: Practical Audit Readiness That Stands Up
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September 24

Testing and Monitoring Programs or Beyond the Checklist: Testing and Monitoring That Uncovers Real Risk