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#1747605 - 10/09/12 03:56 PM
Approved, Not Accepred or Denial
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Platinum Poster
Joined: May 2008
Posts: 915
Orlando, FL
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Application was made for const/perm loan for a primary residence. The Bank made a counter offer. The applicant did not accept and went with another lender.
For HMDA, the action taken is a denial, correct?
And, the action taken date is the date in which the applicant contacted the bank and indicated they did not accept the counter offer, right?
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#1747609 - 10/09/12 04:02 PM
Re: Approved, Not Accepred or Denial
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Idaho
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Correct on both.
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#1747620 - 10/09/12 04:21 PM
Re: Approved, Not Accepred or Denial
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I think your action taken date would be whatever the date of your denial is, not the date they contact you and say they don't want to accept your counteroffer.
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#1747630 - 10/09/12 04:30 PM
Re: Approved, Not Accepred or Denial
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Idaho
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You're right raitchjay, I forgot this was a counter-offer situation.
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#1747651 - 10/09/12 04:51 PM
Re: Approved, Not Accepred or Denial
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Orlando, FL
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So, then if the applicant calls on 10/5 to say they do not accept the counter offer and the bank notates the file regarding this and closes it on 10/9, the action taken date is 10/9?
And, on a related note, since they aren't actually denying (it was a counter offer not accepted), an AAN is not necessary?
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#1747661 - 10/09/12 04:59 PM
Re: Approved, Not Accepred or Denial
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A counteroffer not accepted IS a denial (you wouldn't grant credit on the terms applied for). Your action taken date is when you issued the denial/counteroffer and yes, you would need an AAN.
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#1747663 - 10/09/12 04:59 PM
Re: Approved, Not Accepred or Denial
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Idaho
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You're right raitchjay, I forgot this was a counter-offer situation. I think I was right the first time. The action date will be the date that the applicant withdrew. So, then if the applicant calls on 10/5 to say they do not accept the counter offer and the bank notates the file regarding this and closes it on 10/9, the action taken date is 10/9?
And, on a related note, since they aren't actually denying (it was a counter offer not accepted), an AAN is not necessary? You're action date would be 10/5 and you would have to send out an AAN.
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#1747665 - 10/09/12 05:00 PM
Re: Approved, Not Accepred or Denial
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The applicant didn't withdraw. They didn't accept the counteroffer which is a denial.
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#1747666 - 10/09/12 05:03 PM
Re: Approved, Not Accepred or Denial
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Anything short of the loan closing in your bank's name after making a counteroffer is a denial. The applicant can't "withdraw" after you've denied credit on the terms applied for and instead make a counteroffer.
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#1747674 - 10/09/12 05:16 PM
Re: Approved, Not Accepred or Denial
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Idaho
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You're correct. I used the wrong verbiage.
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#1747690 - 10/09/12 05:53 PM
Re: Approved, Not Accepred or Denial
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Orlando, FL
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Okay...so now I am confused....bottom line: If the applicant did not accept the counter offer (which was issued on 9/20), the HMDA action taken date would be 10/5 (the date the applicant did not accept the offer)???
Or, is the action taken date 10/9 (the date the bank closed the file)??
And, should the bank have issued a final denial notice on 10/9?
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#1747699 - 10/09/12 06:01 PM
Re: Approved, Not Accepred or Denial
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Orlando, FL
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The counter-offer did not list reasons why the request wasn't granted as applied...it just had the counter-offer details. So, essentially, they should have issued a denial notice specifying the reasons for denial.
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#1747728 - 10/09/12 06:40 PM
Re: Approved, Not Accepred or Denial
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