Thanks, what I am looking for is, when you "prequal" someone, do you consider this a Reg B application and start tracking Notice of Incomplete timeframe, and how many of these do you have that never materialize into anything?

Prequals should have an "end" date after which it no longer applies and the bank closes it out.

It is going to be really hard for you to find this information because the best source of withdrawal information is going to be your HMDA LAR, or you can order HMDA information from the CFPB.

I think, and Just Jay can tell me if I am off base, that he is referring to approved and not accepted under HMDA definitions. Depending on how you treat applications, we only call a full underwriting approval an "approval" under approved and not accepted and thus actually have a significant number of withdrawals.

I differentiate between a preliminary approval and a final approval.

Do you then consider these withdrawn applications?

What I am dealing with is lenders are doing a "prequal" but are not considering it a reg b application, so nothing is ever followed up on, or tracked. We have VERY few withdrawn or denied files a year, and it is a big concern of mine, but am getting push back that these aren't "applications".