For HMDA purposes what defines application. We had a loan declined due to unable to verify income. The lender completed the LAR and stated they had no loan amount. This sounds more like a prequalification and not an application which would not be HMDA reportable. The bank does not have a preapproval program.

1. Consistency with Regulation B.
Board interpretations that appear in the official staff commentary to Regulation B (Equal Credit Opportunity, 12 CFR part 202, Supplement 1) are generally applicable to the definition of an application under Regulation C. However, under Regulation C the definition of an application does not include prequalification requests.

So if the loan was denied we would be required to send an AAN to the borrower under Reg B and not knowing the loan amount it would not be HMDA reportable because it's not an application according to Reg C.

The absence of a loan amount does not make the application a pre-qualification for HMDA purposes. If you had an identified property you had an application for reporting purposes.

What Dan said, if the purpose is purchase and no property identified, it's a prequal and not HMDA reportable. If the purpose is HI or refi, it is reportable.

(I had one LO try to sell me on a prequal for refi, ummmm, no, you have a property.)