A further question on this point:
"I agree common sense would make it incomplete, BUT the way I read HMDA, it says I can only use Incomplete as the Action Taken if I sent the notice of incompleteness as described under Reg. B asking the customer to supply additional information by a specific date. All we've really asked the customer is whether he wants to continue with the loan process."
If you have a file that does not indicate approval anywhere, (i.e. it is clearly an incomplete file) BUT no Reg B notice of incompleteness was sent [ECOA problem], can you still report it on the HMDA-LAR as incomplete? If not, what do you report it as?