If you deny an application and then the applicant comes back in with more information and you approve the loan, how would you report this under HMDA? Once or twice?

Did you deny with a counteroffer, or did you simply send out an adverse action notice?

We operate with a centralized underwriting area. If a banker re-sends the entire application for underwriting, and the deal is assigned a new underwriting number, we report it twice. If the banker just sends in the new information and asks the underwriter to look at the deal again with the new info (using the same underwriting number), we report it once.

You have the option to treat it as 1 or 2 applications (page D-10 in the GIR). I like Hmdagal's approach.