We denied a customer for a particular loan type but are continuing to do their loan under a different loan type. Would we have 2 HMDA LAR entries - one for the denial, another for the origination? Or would we just have one entry for the origination? It is for the same subject property.

Thank you.

If it's a reinstated application you have your choice.

3. Application date—reinstated application. If, within the same calendar year, an applicant asks a financial institution to reinstate a counteroffer that the applicant previously did not accept (or asks the institution to reconsider an application that was denied, withdrawn, or closed for incompleteness), the institution may treat that request as the continuation of the earlier transaction using the same ULI or as a new transaction with a new ULI. If the institution treats the request for reinstatement or reconsideration as a new transaction, it reports the date of the request as the application date. If the institution does not treat the request for reinstatement or reconsideration as a new transaction, it reports the original application date.


If it's an accepted counteroffer I would only report the origination.