Our mortgage dept has a pre-qualification form they use when a customer would like to see if they pre-qualify to purchase a home. We do not get property addresses on these so they are not considered "true" applications. If a customer withdraws his request for pre-qualification before an "approve or decline" is communicated would we still need to send an adverse action letter?

Do we send adverse action if we decline a pre-qual? We are pulling credit most of the time.

No adverse action needed for a withdrawn application, as nothing adverse has occurred.

When an applicant withdraws their request before a decision is made there has been no adverse action taken therefore an AAN is not required.

If you deny a pre-qual it becomes an application for the purposes of Reg B's 202.9 notification requirements. Review the discussion of what is an application in the Commentary to 202.2.