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#2162057 - 01/26/18 04:52 PM PreApproval Requested or Not
Compliance Newbie Offline
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Joined: Jan 2015
Posts: 79
We use HMDA Wiz and so far all my 2018 loans have a Validity Error V613. We DO NOT have a PreApproval Program with our bank and I have all my records coded a 2. Preapproval Not Requested. But the FIG says if the record is coded 1. Originated Loan then it must be coded 1. Preapproval Requested. I'm having a hard time wrapping my head around this one. How can we code it Preapproval Requested when we don't have a Preapproval Program?

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#2162077 - 01/26/18 05:33 PM Re: PreApproval Requested or Not Compliance Newbie
Red Raiders Offline
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If you don't have a preapproval program you would enter "2" for Preapproval. Not sure why you are getting the validity error. I also don't see in the FIG where you say it says that if you code a loan as originated that the Preapproval has to be a "1".
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#2162083 - 01/26/18 05:53 PM Re: PreApproval Requested or Not Compliance Newbie
Dan Persfull Offline
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Bloomington, IN
I would be talking to HMDA Wiz since they are responsible for the programming. It's just speculation but it sounds like they are still running "2017" validity checks which would require a code 3 instead of code 2.
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#2162088 - 01/26/18 06:08 PM Re: PreApproval Requested or Not Compliance Newbie
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Joined: Jan 2015
Posts: 79
From the FIG:

An invalid Preapproval data field was provided. Please review the information below and update your file accordingly.
1) Preapproval must equal 1 or 2, and cannot be left blank.
2) If Action Taken equals 7 or 8, then Preapproval must equal 1.
3) If Action Taken equals 3, 4, 5 or 6, then Preapproval must equal 2.
4) If Preapproval equals 1, then Action Taken must equal 1, 2, 7 or 8.

HMDA Wiz just refers back to the FIG.

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#2162092 - 01/26/18 06:17 PM Re: PreApproval Requested or Not Compliance Newbie
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I'm just going from what you posted, but nothing there states that if Action Taken equals 1, Preapproval must equal 1?
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#2162093 - 01/26/18 06:18 PM Re: PreApproval Requested or Not Compliance Newbie
cgorham Offline
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Joined: Sep 2015
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I think the logic is backwards. The edit is saying that if Preapproval is yes, then the action taken must be loan originated, ANA, Preapproval denied, or preapproval approved but not accepted. You are saying that everything that is loan originated must be yes for preapproval. The FIG only says the preapproval must be yes if the action taken is 7 or 8.

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#2162100 - 01/26/18 06:45 PM Re: PreApproval Requested or Not Compliance Newbie
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Joined: Jan 2015
Posts: 79
Thanks cgorham. I'll try that logic with them.

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