We have an applicantfor which an approval was obtained and commitment letter was issued, the borrower withdrew the requiest due to the purchase/sale contract fell through. How would this transaction be reported in HMDA, approved but not accepted or withdrawn.

We would report approved but not accepted.

Thank you.

If the customer withdraws BEFORE a credit decision is made, we handle as withdrawn. If loan is approved with underwriting-related conditions that the borrower doesn't meet or decides not to go through with, we report as denied. If a loan is approved with closing-related conditions that the borrower doesn't meet or decides not to go through with, we report as "approved but not accepted." That is our understanding of HMDA reporting rules.

We had this same scenario, however, now six months later the borrower is back to purchase the property with a new sales contract. I am assuming we report both applications and end up with the same property on our LAR twice.

Appendix D, page D-9 states the following:

3. Application date—reinstated application. If, within the same calendar year, an applicant asks an institution to reinstate a counteroffer that the applicant previously did not accept (or asks the institution to reconsider an application that was denied, withdrawn, or closed for incompleteness), the institution may treat that request as the continuation of the earlier transaction or as a new transaction. If the institution treats the request for reinstatement or reconsideration as a new transaction, it reports the date of the request as the application date.