We are a HMDA reporting bank which is creating issues with the prequals and preapprovals. Currently our practice is to allow a prequal but as markets grow so we begin the cross over. I understand there are four elements in a "preapproval" program and there is the adhoc piece. In reviewing our current practices, I don't feel we can rely on the ad hoc exemption. I am receiving more requests for a preapproval program. I think it will come down to strongly adhering to our practice or moving into the next stage of the game. I would appreciate any feed back regarding your processes. Nothing is simple in our world. THANKS!

We elected to adhere to the prequal only.
A quick look at the credit report and a warm fuzzy 'if/then' letter have sufficed for borrowers to use while shopping.