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#1815705 - 05/20/13 02:24 PM Pseudo-denial of part of applicant group - report?
Tater Offline
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Missouri
One I've never run across and I'm struggling to find proof to support my hypothesis.

Mom / Dad / Son apply for a loan. Son is poor credit risk and declined based on credit history and dti ratio because he has no ongoing income. Mom and Dad continue through process and are heading to origination.

Is full application of Mom/Dad/Son reportable as denial, is son reported as denied, or since there's no "new" application (kind of following the path of a counter-offer being accepted), don't report anything about son and just report the anticipated origination for Mom & Dad?

Too early on a Monday for this.
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#1815809 - 05/20/13 05:53 PM Re: Pseudo-denial of part of applicant group - report? Tater
RR Joker Offline
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The Swamp
I would be reporting as an origination on Mom/Dad.
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#1815914 - 05/20/13 07:40 PM Re: Pseudo-denial of part of applicant group - report? Tater
Kathleen O. Blanchard Offline

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Agree. Origination on Mom/Dad. You report your end result.
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#1815920 - 05/20/13 07:46 PM Re: Pseudo-denial of part of applicant group - report? Tater
Tater Offline
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Missouri
Thanks folks - that is what I was thinking, too, but couldn't find support to be certain. One of those days smile

Have a great day!
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Born once? Die twice.
Born twice? DIE ONCE!

Loan Review, HMDA, ALLL

Opinions are my own and do not reflect any others

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#1815922 - 05/20/13 07:47 PM Re: Pseudo-denial of part of applicant group - report? Tater
Marnie Offline
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Posts: 437
Nevada
Wow. I have to disagree. The first app is a denial and reported as such. Parents decided to move foward on their own, so now you have a second application, with date of application when they decided to go on their own, and action date when they were approved on their own. This is for both HMDA and REG B, as son should get an adverse action letter with reasons, and the same denial reasons would be put on the HMDA LAR.

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#1815936 - 05/20/13 08:05 PM Re: Pseudo-denial of part of applicant group - report? Tater
Kathleen O. Blanchard Offline

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They did not necessarily start a new ap. If they did, you would deny the first and start a new one. If you counteroffered, you can just move forward.
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#1815937 - 05/20/13 08:05 PM Re: Pseudo-denial of part of applicant group - report? Tater
Dan Persfull Offline
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Bloomington, IN
I agree son must receive an AAN under Reg. B but if mom & dad were counter-offered to make the loan in their names only and they accepted then an accepted counteroffer is reported as an origination.
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#1815940 - 05/20/13 08:07 PM Re: Pseudo-denial of part of applicant group - report? Tater
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Yes, I was just going to post that the son receiving a denial under B does not necessarily affect HMDA reporting. If a bank wants to start a new ap, that is one thing, but it is not required.
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Kathleen O. Blanchard, CRCM "Kaybee"
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