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#1639495 - 12/15/11 04:49 PM 2 loans one app and a Counter
AFaquir Offline
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AFaquir
Joined: Jan 2011
Posts: 763
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Scenario:

Customer comes in asks for a Refi-loan.

Loan is denied due to appraisal, but counter offer is made for a lower loan refi amount and a second Home Equity Loan (for home improvement)...

Customer "verbally" accepts the couter, so we open the home equity loan file on our system. After about 10 days customer decides they do not want to make EITHER loan...

How the heck do I close these and count these on my HMDA... the Refi one is easy, but what do I do with this home improvement loan? I only have the one app and a counter offer but it created two loans on my LAR...

Any help would be appreciated!

Cheers!
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#1639515 - 12/15/11 05:17 PM Re: 2 loans one app and a Counter AFaquir
Brent B Offline
Member
Joined: Jul 2011
Posts: 60
Champaign, IL
You would report as a denial of the original loan request. A counteroffer only is accepted if it results in origination.

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#1639602 - 12/15/11 06:04 PM Re: 2 loans one app and a Counter Brent B
AFaquir Offline
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AFaquir
Joined: Jan 2011
Posts: 763
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So report them both the same... approved not accepted?
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#1639620 - 12/15/11 06:13 PM Re: 2 loans one app and a Counter AFaquir
Island Dreaming Offline
100 Club
Joined: May 2009
Posts: 215
midwest
Search the HMDA Getting it Right Guide for 'counteroffers'. If a counteroffer doesn't result in an origination, you report only the original application as a denial. Given the information from your original post, the denial reason would be collateral value.
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#1639909 - 12/15/11 11:34 PM Re: 2 loans one app and a Counter Island Dreaming
starfish Offline
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starfish
Joined: Jun 2003
Posts: 416
Seattle
I would report one transaction- a denial for the original amount requested by the borrower. Just curious...did the customer sign loan documents for the home equity loan before you put it on your system?

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