Our secondary market department has a preapproval program in place. Our other loan areas do not have a preapproval program.

When an application is received for our secondary market product and a preapproval is not given, we enter the code for "Preapproval Not Requested. When an application is received by one of our other lenders, we enter the code for "Preapproval Not Applicable".

Could this potentially lead to an exam finding, based on inconsistent use of the preapproval code? Or is it OK for us to code the LAR in this manner?

Just have documentation that your "consumer" and commercial mortgages do not have a pre-approval program and you will be fine the way you are reporting.

The old "CYA". Thanks, Dan.