Paragraph 4(a)(14) Determining lien status.....If the applicant discloses a mortgage on the property on the application and chooses a purpose of refinance, we report the lien status as a first lien even if the application was denied or withdrawn, correct? I thought I had this one down, but I recently attended a HMDA class and was told that if the application does not result in an origination, for example, because the application was denied or withdrawn, we report the application as a subordinate lien. Even if the borrower indicates that the existing mortgage will be refinanced. Is anyone else familiar with this?
_________________________
Keep calm, and let the compliance officer handle it....