Customer applied for a purchase money mortgage, we pre-approved but then they withdrew. Lender failed to send out pre-approval letter. Is this still HMDA reportable as a pre-approval requested, application withdrawn.

I don't believe the issuance of (or failure to issue) a letter in any particular instance makes a difference. Assuming you have a preapproval program that meets the restrictions of the regulation, then you're talking about a preapproval request under HMDA.

The reporting of preapprovals that are approved but not accepted by the applicant are optional under HMDA. If you normally report them, then I would report this one as well. Action code would be "8--Preapproval request approved but not accepted"