LOL! So we're splitting hairs now?
Let me re-phrase:
All HMDA reportable loans coming through our secondary market mortgage department, which has a formal preapproval program, are coded 1 or 2 as appropriate.
All HMDA reportable loans coming through our regular loan department (both consumer and commercial), which does not have a formal preapproval program, are coded 3.
Is this better, Dan?
This stuff makes my head spin....
edited to add: After re-reading this, I realize my tone comes across as snarky and I apologize. Of course we're splitting hairs - this is compliance, and I should know better by now than to speak in generalities. At least the complexity grants us some measure of job security, eh?