A customer applied for a loan at a requested rate. We were unable to offer that rate due to the credit score, informed the customer of that, and offered a slightly higher rate. The customer said that they didn't want the loan unless they got the lower rate so they declined to move forward. Is this a denial since we were unable to offer the terms that the customer applied for?

Is this a denial since we were unable to offer the terms that the customer applied for?

Yes.

Thank you!

Dan-
So when the loan is approved at a rate other than applied for because we didn't offer the rate at the rate applied for, what is the HMDA denial reason. We just didn't offer the rate, it had nothing to do with the customer's credit or anthing else in the file.

We approved them on a counter offer and they did not accept it. I have always understood we must then deny on the original request.

But what would the HMDA denail reason be "Other" with an explanation?

But what would the HMDA denail reason be "Other" with an explanation?

Yes. Other: Specific rate requested by applicant is not offered for this product.

However keep in mind the original poster's applicant applied for a specific rate and not just the assumption of the effective rate at the time of application. There is a difference.

If they don't qualify for the posted rate and they don't accept the counteroffer then you have to give the reasons why they did not qualify for your posted rates.

Yes, I understood that but thanks for making sure.

Hi all

If we incorrectly determined a loan was "Withdrawn" and sent the AA notice only to find in an audit (months later) that it should have been "Denied", should we now send a corrected AA notice to the borrower(s)? What should we use for our action date? The original date the "Withdrawn" AA was issued or the date of the corrected one?

Thanks!

I think your bigger issue might be with sending AANs to applicants who withdraw. An applicant withdrawing their loan request doesn't experience adverse action and shouldn't be sent an AAN.

Thanks raitchjay however I may have misspoken. I am not certain an AA notice was originally sent. I'm not in a complance role here but was asked my opinion on the matter and I may have the details a little messed up. So let's assume an AA wasn't sent. Do we now send one? Do we use the current date as the date of action? Thanks!

If you're talking about a consumer application, if you verbally notified the consumer of the denial at the time you denied it, i'd sent the AAN out late (better late than never) and use the action taken date of the verbal denial. If the verbal denial never happened, i'd probably still send the AAN out late, using today's date as the action taken date. Just my opinion.