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#1695818 - 05/04/12 03:10 PM Prequalification denied- now app/ HMDA reportable
CaseyBoo30 Offline
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Joined: Feb 2007
Posts: 262
Winchester, KY
If a prequalification was denied (adverse action notice sent) changing it from an inquiry to an application, and the application is missing key information needed for hmda reporting, how should this be handled?

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#1695837 - 05/04/12 03:28 PM Re: Prequalification denied- now app/ HMDA reportable CaseyBoo30
raitchjay Online
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Joined: Oct 2009
Posts: 8,674
OK
Denied prequals aren't HMDA reportable. See the GIR.
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#1695858 - 05/04/12 03:42 PM Re: Prequalification denied- now app/ HMDA reportable CaseyBoo30
CaseyBoo30 Offline
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Posts: 262
Winchester, KY
In FIL-35-96 is says that once a loan officer has denied a prequalification that it then becomes an application and Reg B and Reg C documenation requirements are triggered.

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#1695864 - 05/04/12 03:49 PM Re: Prequalification denied- now app/ HMDA reportable CaseyBoo30
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,277
From the current GIR (this instruction supercedes old 1996 guidance):

2. Prequalification. A prequalification
request is a request by a prospective
loan applicant (other than a request
for preapproval) for a preliminary
determination on whether the prospective
applicant would likely qualify
for credit under an institutionís standards,
or for a determination on the
amount of credit for which the prospective
applicant would likely qualify.
Some institutions evaluate prequalification
requests through a procedure
that is separate from the institutionís
normal loan application process; others
use the same process. In either
case, Regulation C does not require
an institution to report prequalification
requests on the HMDA/LAR, even
though these requests may constitute
applications under Regulation B for
purposes of adverse action notices.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1695871 - 05/04/12 03:54 PM Re: Prequalification denied- now app/ HMDA reportable CaseyBoo30
CaseyBoo30 Offline
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Joined: Feb 2007
Posts: 262
Winchester, KY
Thank you very much.

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#1695878 - 05/04/12 04:09 PM Re: Prequalification denied- now app/ HMDA reportable CaseyBoo30
CaseyBoo30 Offline
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Joined: Feb 2007
Posts: 262
Winchester, KY
One more question. If the loan officer obtained monitoring information on the denied prequalificatio, is this an issue since it is not HMDA reportable? Or does the FIL come back into play since it is an application for Reg. B purposes.

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#1759779 - 11/20/12 11:09 PM Re: Prequalification denied- now app/ HMDA reportable Kathleen O. Blanchard
nikicole03 Offline
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Joined: May 2012
Posts: 6
It states:
Quote:
In either case, Regulation C does not require an institution to report prequalification requests on the HMDA/LAR, even though these requests may constitute applications under Regulation B for purposes of adverse action notices.


It's not required, but are we allowed to report these on the LAR if we have all the required data elements?

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#1759785 - 11/20/12 11:27 PM Re: Prequalification denied- now app/ HMDA reportable CaseyBoo30
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,277
That is their way of saying these are not reportable applications under HMDA.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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