Under HMDA the loan amount for a withdrawn is the same as denied applications - report the amount applied for.

A borrower request $113,091 loan amount. The bank discussed a scenario loan amount of $115,192 with the borrower; which the borrower preferred. However the borrower then withdrawn before an approval was made what loan amont should be reported?

Thank you

If the applicant formally amended the loan request to the $115 then that's what I would report. If it was just discussed and the application was not formally amended by the applicant I would report the $113.

I agree with Dan. Heres what the regulation states about counteroffers:

If an applicant does not accept a counteroffer or fails to respond, the institution reports the loan amount initially requested. [Commentary to §1003.4(a)(7) #1]

The system is updated but new early disclosures are not sent. These are on my LAR as withdrawn. The Mortgage Co we use is not looking at these as counteroffers.

Not sure if I still have an issue. They discuss with the client (phone or in person) and the borrower wanted the $115. But then withdraw.

Dan - what do you mean by formally amended?

Let's say the borrower requested a product change, going from FHA to Conventional and we changed the loan amount. We end up denying the borrower due to income. For HMDA do we go back to what the borrower originally applied for or the requested changes by the borrower?

In general if a borrower requests or accepts changes (i.e. loan amount changes) and then further down in the process the borrower decides to withdraw or we deny for some reason do we report, for HMDA, the changes or what the borrower originally applied for?

Thank you!