Skip to content
GeoDataVision
Thread Options
#2116376 - 01/31/17 09:47 PM Applications Withdrawn rather than Denied
MFlea Offline
New Poster
Joined: Jan 2017
Posts: 17
I just came across a file during my HMDA review that was processed as a withdraw when it should have been denied due to DTI. How can this be fixed if at all? How do I report this on the HMDA LAR?

Return to Top
Lending Compliance
#2116379 - 01/31/17 09:52 PM Re: Applications Withdrawn rather than Denied MFlea
MScarn6942 Offline
Platinum Poster
Joined: Aug 2015
Posts: 756
Land Lacking in Lakes, IL
Is it for 2016 HMDA data or before? If for 2016, correct it and report it as a denial.

Edit: I assumed you have not submitted yet since you're still reviewing... please correct me if I'm wrong!
Last edited by MScarn6942; 01/31/17 09:53 PM. Reason: made assumptions in my original response!
_________________________
"Pressure is something you feel when you don't know what you're doing" - Peyton Manning

Return to Top
#2116383 - 01/31/17 10:06 PM Re: Applications Withdrawn rather than Denied MScarn6942
MFlea Offline
New Poster
Joined: Jan 2017
Posts: 17
Yes, it is for 2016.

For ECOA Compliance since the file has already been processed as a withdraw and borrower never received NOA should I just document the file as "self-identified" error? Or what else can be done?

Return to Top
#2116386 - 01/31/17 10:13 PM Re: Applications Withdrawn rather than Denied MFlea
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 8,840
OK
I'd sent out a late (perhaps very late) AAN. I'd rather correct it late than not at all.
_________________________
I'm fixin' to fix that.

Return to Top
#2116387 - 01/31/17 10:14 PM Re: Applications Withdrawn rather than Denied MFlea
Darth HMDA, CRCM, CAMS Offline
Diamond Poster
Darth HMDA, CRCM, CAMS
Joined: Dec 2013
Posts: 1,387
CA
I would send out the adverse if it has not been sent out yet. (assuming NOA means Notice of Adverse)
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

Return to Top
#2116389 - 01/31/17 10:35 PM Re: Applications Withdrawn rather than Denied MFlea
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,441
Florida
3 pete. Denial on HMDA and AAN.

(Depending on the time), I'd probably send a short note with the AAN apologizing that "our quality control in reviewing your file noted that you had not received your copy". Note it in the file, and use it as a training opportunity.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

Return to Top
#2116395 - 01/31/17 11:05 PM Re: Applications Withdrawn rather than Denied Rocky P
MScarn6942 Offline
Platinum Poster
Joined: Aug 2015
Posts: 756
Land Lacking in Lakes, IL
Originally Posted By Rocky P
I'd probably send a short note with the AAN apologizing that "our quality control in reviewing your file noted that you had not received your copy".


This is a really nice touch and goes a long way in helping to avoid confusing the recipient!
_________________________
"Pressure is something you feel when you don't know what you're doing" - Peyton Manning

Return to Top

Moderator:  Andy_Z