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#1989462 - 01/16/15 09:05 PM
Re: Are pre-qualifications HMDA reportable?
solbrillante
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Power Poster
Joined: Aug 2001
Posts: 7,351
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Pre-qualification requests are not reportable.
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The more you sweat in training, the less you bleed in battle.......
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#1989471 - 01/16/15 09:17 PM
Re: Are pre-qualifications HMDA reportable?
solbrillante
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Power Poster
Joined: Aug 2001
Posts: 7,351
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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.
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The more you sweat in training, the less you bleed in battle.......
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#1989486 - 01/16/15 09:51 PM
Re: Are pre-qualifications HMDA reportable?
solbrillante
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Power Poster
Joined: Oct 2009
Posts: 9,105
OK
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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?
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#1989508 - 01/16/15 11:30 PM
Re: Are pre-qualifications HMDA reportable?
solbrillante
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Power Poster
Joined: Jun 2001
Posts: 8,272
Where the heart is
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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.htmSee pages 9, 12, and D-2, which by the way has a very extensive discourse on Pre-Qualifications and Pre-Approvals: 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. 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.
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CRCM,CAMS Regulations are a poor substitute for ethics. Just sayin'
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#1992850 - 02/02/15 05:53 PM
Re: Are pre-qualifications HMDA reportable?
solbrillante
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Diamond Poster
Joined: May 2013
Posts: 1,782
The Mitten State
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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?
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Nonsense wakes up the brain cells.
--Dr. Seuss
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#1992855 - 02/02/15 05:54 PM
Re: Are pre-qualifications HMDA reportable?
solbrillante
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Power Poster
Joined: Aug 2001
Posts: 7,351
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No. Once an address is idenitified, it can no longer be a pre-approval request.
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The more you sweat in training, the less you bleed in battle.......
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#1992867 - 02/02/15 06:05 PM
Re: Are pre-qualifications HMDA reportable?
solbrillante
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Diamond Poster
Joined: May 2013
Posts: 1,782
The Mitten State
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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
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#1992870 - 02/02/15 06:11 PM
Re: Are pre-qualifications HMDA reportable?
solbrillante
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10K Club
Joined: Dec 2000
Posts: 21,293
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#1992874 - 02/02/15 06:12 PM
Re: Are pre-qualifications HMDA reportable?
solbrillante
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Diamond Poster
Joined: May 2013
Posts: 1,782
The Mitten State
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Thanks!
_________________________
Nonsense wakes up the brain cells.
--Dr. Seuss
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#1992895 - 02/02/15 06:45 PM
Re: Are pre-qualifications HMDA reportable?
solbrillante
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Power Poster
Joined: Aug 2001
Posts: 7,351
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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.
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The more you sweat in training, the less you bleed in battle.......
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#1992998 - 02/02/15 11:17 PM
Re: Are pre-qualifications HMDA reportable?
solbrillante
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Power Poster
Joined: Aug 2001
Posts: 7,351
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Nope....my brain got sideways and I thought I was answering that as well. Happy Monday.
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The more you sweat in training, the less you bleed in battle.......
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#2259244 - 09/03/21 03:26 PM
Re: Are pre-qualifications HMDA reportable?
Kathleen O. Blanchard
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New Poster
Joined: Aug 2021
Posts: 8
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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?
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#2259257 - 09/03/21 07:00 PM
Re: Are pre-qualifications HMDA reportable?
solbrillante
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10K Club
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
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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).
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The opinions expressed are mine and they are not to be taken as legal advice.
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#2259271 - 09/03/21 08:45 PM
Re: Are pre-qualifications HMDA reportable?
solbrillante
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New Poster
Joined: Aug 2021
Posts: 8
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Thanks Dan. As always a great help! ;>)
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#2259281 - 09/04/21 01:54 PM
Re: Are pre-qualifications HMDA reportable?
solbrillante
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Power Poster
Joined: Jun 2003
Posts: 7,658
Florida
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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.
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Integrity. With it, nothing else matters. Without it, nothing else matters.
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