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#175770 - 04/01/04 09:51 PM HMDA Denied?
Georgia Golfer Offline
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Georgia Golfer
Joined: Jun 2003
Posts: 415
1st Tee
2 scenarios:
1. Husband & Wife sign app and authorization to pull credit. Credit report is pulled and right away it is obvious that his score will cause problems, so without submitting to underwriting they revise the app for just her and submit...2 HMDA entries? 1 denial & 1 approval? I don't think it's 2 since the first was never sent to underwriting to be approved or not.
2. Same couple, get app and start to complete , but sign authorization and credit is pulled as they are filling in the app. Same thing, his credit is terrible so they cross out his info and she is the only one to sign and date the app. Same question...2 entries or 1?

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Lending Compliance
#175771 - 04/01/04 10:39 PM Re: HMDA Denied?
hmdagal Offline
Power Poster
hmdagal
Joined: Dec 2002
Posts: 3,841
My vote is for 2 HMDA entries. If the husband didn't intend to apply, why would you have pulled credit?

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#175772 - 04/02/04 05:10 AM Re: HMDA Denied?
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
I think you have one entry and here's my reasoning:

1. You had 2 applicants and pulled credit on both. A credit decision was made based on the credit report (in both scenarios).

2. You counteroffered to make the loan only in the wife's name. Your counteroffer would give the reasons for the original request being denied and you would owe the husband a FCRA notice.

3. The wife accepted the counteroffer (I assume) therefore you have an origination.

4. If the wife did not accept the counteroffer then you have one denial.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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