KamoCRM

A person's denial starts the ECOA notice clock, when the lender tracks it

FeatureSecurityService
Shipped
October 28, 2026 at 3:54 PM UTC
Author
Kamo
Commit
9358040

Only an automated-underwriting decoder armed the 30-day adverse-action clock, so a loan a person denied in Kamo never showed a notice owed on the Adverse Action report. AdverseActionClock now arms the same timer after a person's move through the pipeline to Denied, Closed for Incompleteness or Pre-Approval Denied — only while the lender has LOAN_ADVERSE_ACTION_CLOCK on (owner, 2026-10-28; off by default), never for an outcome synced from another system, once per live clock, and never failing the move. Tracking only; nothing is sent. Written through the EntityManager (SecurityService does not register the compliance repositories); its query is compiled on the fleet's Hibernate.

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