We are not a HMDA reporting bank. A consumer requested and received a regular application and returned it stating the purpose was for a home purchase. It was denied within the 3 days. Do we need to have monitoring information and/or a completed real estate loan application?

Reg B 202.13 requires you to get the monitoring info if the app was taken in person and if the purpose was for the purchase of or the refinance of the persons primary residense. As the reg does not require the application to be signed by the customer you could fill one out from the app they did complete. You have to have a written app if the loan is for purchase of or refinance of the primary residence. 202.5(e)& 202.13(a)