We have a refinance of a primary residence, but then the borrower calls to withdraw before providing their income information. Would I just use NA for income in this instance or would this not be HMDA reportable?
The borrower applied for a loan to refinance. This sounds like an application either 1) withdrawn or 2) closed for incompleteness...but either way, reportable. If their income wasn't considered, it's reported NA. Since they withdrew before you issued 'info needed to complete'...I would vote door #1.
Last edited by RR Joker; 05/22/1705:12 PM.
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My opinion only. Not legal advice.
but then the borrower calls to withdraw before providing their income information
'borrower called to withdraw' << that's your HMDA action code.
I would not be so quick to classify as withdrawn with the information known.
Was the applicant asked for the income information and they decided not to provide it and said they changed their minds? If so you have a denial for an incomplete application.
If they withdrew before any underwriting information was requested then I would agree with withdrawn.
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The opinions expressed are mine and they are not to be taken as legal advice.