Skip to content
BOL Conferences
Thread Options
#1989429 - 01/16/15 08:07 PM Are pre-qualifications HMDA reportable?
solbrillante Offline
Member
solbrillante
Joined: May 2011
Posts: 85
We don't have a pre-approval program as defined in HMDA. We have a few applications customers submitted and they were either withdrawn or denied for credit. They never provided a property address. They did not have a preperty to purchase yet and they were just shopping around. It is my understanding that when there is no property address, it's not an application for HMDA purposes ; therefore, not reportable. I pulled this from a 1996 FDIC Guide. Is this no longer the case?

Return to Top
HMDA

   
HMDA Academy
#1989462 - 01/16/15 09:05 PM Re: Are pre-qualifications HMDA reportable? solbrillante
swiggles Offline
Power Poster
swiggles
Joined: Aug 2001
Posts: 7,351
Pre-qualification requests are not reportable.
_________________________
The more you sweat in training, the less you bleed in battle.......

Return to Top
#1989467 - 01/16/15 09:09 PM Re: Are pre-qualifications HMDA reportable? solbrillante
solbrillante Offline
Member
solbrillante
Joined: May 2011
Posts: 85
I have a someone who disagrees with me. And since my only source is a 1996 guide, not much to stand on. The Getting It Right guide and the reg don't say much about it, other than pre-quals are not reportable.

Return to Top
#1989471 - 01/16/15 09:17 PM Re: Are pre-qualifications HMDA reportable? solbrillante
swiggles Offline
Power Poster
swiggles
Joined: Aug 2001
Posts: 7,351
The FFIEC's "HMDA Getting it Right" states not to report pre-qualification requests. See page 9

Transactions Not to Be Reported (bullet 8) "Prequalification requests for mortgage loans, as opposed to preapproval requests, which must be reported See comment 1003.2 (Application)-2"

Just remember....if an application bears an address, it can't be a pre-qual or a pre-approval. It's an application.
_________________________
The more you sweat in training, the less you bleed in battle.......

Return to Top
#1989486 - 01/16/15 09:51 PM Re: Are pre-qualifications HMDA reportable? solbrillante
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 9,105
OK
Originally Posted By: solbrillante
The Getting It Right guide and the reg don't say much about it, other than pre-quals are not reportable.


Truly not trying to be sarcastic at all, just trying to understand: what else do you need or want it to say?
_________________________
I'm fixin' to fix that.

Return to Top
#1989508 - 01/16/15 11:30 PM Re: Are pre-qualifications HMDA reportable? solbrillante
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Originally Posted By: solbrillante
I have a someone who disagrees with me. And since my only source is a 1996 guide, not much to stand on. The Getting It Right guide and the reg don't say much about it, other than pre-quals are not reportable.


I'm sorry, but how can the 1996 Guide be your only source?

Here is the FFIEC page with link to the PDF file of 2013 Guide right near the top:
http://www.ffiec.gov/hmda/guide.htm

See pages 9, 12, and D-2, which by the way has a very extensive discourse on Pre-Qualifications and Pre-Approvals:

Quote:
2.
Prequalification. A prequalification request is a request by a prospective loan applicant (other than a request for preapproval) for a preliminary determination on whether the prospective applicant would likely qualify for credit under an institution’s standards, or for a determination on the amount of credit for which the prospective applicant would likely qualify. Some institutions evaluate prequalification requests through a procedure that is separate from the institution’s normal loan application process; others use the same process. In either case, Regulation C does not require an institution to report prequalification requests on the HMDA/ LAR, even though these requests may constitute applications under Regulation B for purposes of adverse action notices.


Quote:
3.
Requests for preapproval. To be a covered preapproval program, the written commitment issued under the program must result from a full review of the creditworthiness of the applicant, including such verification of income, resources, and other matters as is typically done by the institution as part of its normal credit evaluation program. In addition to conditions involving the identification of a suitable property and verification that no material change has occurred in the applicant’s financial con dition or creditworthiness, the written commitment may be subject only to other conditions (unrelated to the financial condition or creditworthiness of the applicant) that the lender ordinarily attaches to a traditional home mortgage application approval. These conditions are limited to conditions such as requiring an acceptable title insurance binder or a certificate indicating clear termite inspection, and, in the case where the applicant plans to use the proceeds from the sale of the applicant’s present home to purchase a new home, a settlement statement showing adequate proceeds from the sale of the present home.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

Return to Top
#1989512 - 01/17/15 01:13 PM Re: Are pre-qualifications HMDA reportable? solbrillante
solbrillante Offline
Member
solbrillante
Joined: May 2011
Posts: 85
I think her issue is not the fact that pre-qualifications are not HMDA reportable, but that the particular samples I have are not pre-qualifications. These applications don't have a property listed and some of them don't even have a loan amount. In some of them we don't have a full underwriting either. So I am trying to argue with this person that the applications on hand are pre-qualifications.

Thanks for everyone for your input.

Return to Top
#1989518 - 01/17/15 04:31 PM Re: Are pre-qualifications HMDA reportable? solbrillante
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
There should not be a property for a preapproval or prequalification, and the applicant needn't specify an amount. The bank is going to tell them what they qualify for. A preapproval must be fully underwritten for credit; the approval is subject only to an acceptable property and relatec property conditions.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#1992850 - 02/02/15 05:53 PM Re: Are pre-qualifications HMDA reportable? solbrillante
JWills, CRCM Offline
Diamond Poster
JWills, CRCM
Joined: May 2013
Posts: 1,782
The Mitten State
I have an application that started as a pre-approval, (customer requested), found a home, started loan process, appraisal came in too low so turned into a denied application. Would I still report as a pre-approval now that I have a property identified?
_________________________
Nonsense wakes up the brain cells.

--Dr. Seuss

Return to Top
#1992855 - 02/02/15 05:54 PM Re: Are pre-qualifications HMDA reportable? solbrillante
swiggles Offline
Power Poster
swiggles
Joined: Aug 2001
Posts: 7,351
No. Once an address is idenitified, it can no longer be a pre-approval request.
_________________________
The more you sweat in training, the less you bleed in battle.......

Return to Top
#1992866 - 02/02/15 06:05 PM Re: Are pre-qualifications HMDA reportable? solbrillante
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
But for the preapproval code itself you will report that a preapproval was requested. Your denial is a regular loan denial, not a denied preapproval request.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#1992867 - 02/02/15 06:05 PM Re: Are pre-qualifications HMDA reportable? solbrillante
JWills, CRCM Offline
Diamond Poster
JWills, CRCM
Joined: May 2013
Posts: 1,782
The Mitten State
Ok, so on my HMDA LAR, I would report as preapproval requested (1) and then action take would be denial (3) not a (7) correct?
_________________________
Nonsense wakes up the brain cells.

--Dr. Seuss

Return to Top
#1992870 - 02/02/15 06:11 PM Re: Are pre-qualifications HMDA reportable? solbrillante
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Yes.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#1992874 - 02/02/15 06:12 PM Re: Are pre-qualifications HMDA reportable? solbrillante
JWills, CRCM Offline
Diamond Poster
JWills, CRCM
Joined: May 2013
Posts: 1,782
The Mitten State
Thanks!
_________________________
Nonsense wakes up the brain cells.

--Dr. Seuss

Return to Top
#1992895 - 02/02/15 06:45 PM Re: Are pre-qualifications HMDA reportable? solbrillante
swiggles Offline
Power Poster
swiggles
Joined: Aug 2001
Posts: 7,351
Duh....I didn't reason that one out before answering. I really WAS thinking it would NOT be reported as a request for pre-approval. It's been so long since I've had any dealings with pre-approval requests, guess I had a brain [censored]. I haven't been at a bank than had or has a pre-approval program since 2009.
_________________________
The more you sweat in training, the less you bleed in battle.......

Return to Top
#1992993 - 02/02/15 10:52 PM Re: Are pre-qualifications HMDA reportable? solbrillante
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
I thought you answered the denial part (correctly)! My intent was to clarify the preap code itself!
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#1992998 - 02/02/15 11:17 PM Re: Are pre-qualifications HMDA reportable? solbrillante
swiggles Offline
Power Poster
swiggles
Joined: Aug 2001
Posts: 7,351
Nope....my brain got sideways and I thought I was answering that as well. Happy Monday.
_________________________
The more you sweat in training, the less you bleed in battle.......

Return to Top
#2259244 - 09/03/21 03:26 PM Re: Are pre-qualifications HMDA reportable? Kathleen O. Blanchard
Donnie Offline
New Poster
Joined: Aug 2021
Posts: 8
Ms. Blanchard, this thread is old so I want to ask you if you think the language "conducts a comprehensive analysis of the applicant's credit worthiness (including income verification) is no longer the litmus test. Meaning does the analysis have to include income verification? If we haven't yet verified income, but we have pulled credit and we have performed an analysis as to the request and looked at DTI, length of empl, etc., would this be considered a comprehensive analysis and change a prequalification to a preapproval?

Return to Top
#2259257 - 09/03/21 07:00 PM Re: Are pre-qualifications HMDA reportable? solbrillante
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
You either have a pre-approval program or you do not (1003.2(b)(2)). An ad-hoc preapproval would not be a preapproval for HMDA reporting purposes.

2021 GIR page I-32

Paragraph 4(a)(4)
1. Request under a preapproval program. Section 1003.4(a)(4) requires a financial institution to
report whether an application or covered loan involved a request for a preapproval of a home
purchase loan under a preapproval program as defined by § 1003.2(b)(2). If an application or
covered loan did not involve a request for a preapproval of a home purchase loan under a
preapproval program as defined by § 1003.2(b)(2), a financial institution complies with
§ 1003.4(a)(4) by reporting that the application or covered loan did not involve such a request,
regardless of whether the institution has such a program and the applicant did not apply through
that program or the institution does not have a preapproval program as defined by
§ 1003.2(b)(2).
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#2259271 - 09/03/21 08:45 PM Re: Are pre-qualifications HMDA reportable? solbrillante
Donnie Offline
New Poster
Joined: Aug 2021
Posts: 8
Thanks Dan. As always a great help! ;>)

Return to Top
#2259281 - 09/04/21 01:54 PM Re: Are pre-qualifications HMDA reportable? solbrillante
Rocky P Online
Power Poster
Joined: Jun 2003
Posts: 7,658
Florida
Donnie, thinking of the 5 C's of credit
Character - the intent to repay - credit score
Capacity - the ability to repay - DTI
Capital - the down payment - LTV (equity)
Conditions - term of the loan,rate, ARM, # years etc.
Collateral - actual property.

A pre-approval program covers the first 4 C's. The lender nails it shut. The ONLY thing left is for the applicant to find collateral. Since the first 4 are already done, the borrower is pre-approved subject to acceptable collateral, nothing more.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

Return to Top

Moderator:  SMQ, CRCM