When an application is approved but not accepted, are we supposed too be reporting on the new HMDA data fields, (CLTV, DT, Note Rate, Rate Spread, etc) ?

For some reason I am really getting hung up on this in regards too denials and w/d's. The old HMDA was not an issue, but these new data fields, and when too report them, and when not too report them is really giving me so much anxiety!! And the worse part is I'm having too go behind someone that was doing our HMDA Jan-Mar and fixing errors.

https://www.ffiec.gov/hmda/guide.htm

Go to page 44 of the FIG and use the "Reporting Not Applicable" column.

Thank you

I have read and reviewed the FIG but I am still hung up on this. Can anyone let me know how they interrupt this?

Ex: Credit.....when not too report it? We run credit on every application that comes in too apply for credit, it is part of our process. So I would think we would always report it unless it's a w/d then I do see where we would not report that. On denials, we have been reporting the credit, even if it wasn't the reason of denial.

But what is hanging me up is the approved but not accepted applications.

3. Action taken—application approved but not accepted. A financial institution reports application approved but not accepted if the financial institution made a credit decision approving the application before closing or account opening, subject solely to outstanding conditions that are customary commitment or closing conditions, but the applicant or the party that initially received the application fails to respond to the financial institution's approval within the specified time, or the closed-end mortgage loan was not otherwise consummated or the account was not otherwise opened. See comment 4(a)(8)(i)-13.


If the approval is conditional on any underwriting requirement such as verification of income then it is not an approved but not accepted.

ii. Customary commitment or closing conditions. Customary commitment or closing conditions include, for example: a clear-title requirement, an acceptable property survey, acceptable title insurance binder, clear termite inspection, a subordination agreement from another lienholder, and, where the applicant plans to use the proceeds from the sale of one home to purchase another, a settlement statement showing adequate proceeds from the sale.

Most of our approved but not accepted are applications that we have approved, sent out the loan estimates, and then applicant decides that they are going too look elsewhere, or hold off for now because they seen by the LE's that their payment will be more than they can handle, etc.

How can you approve a loan is not subject to underwriting conditions before sending the LE?

We do. Our conditions are once the credit application is received, then the l.o. reviews their income credit, etc. and once approved our loan dept. prints the L.E.'s if the credit request is approved by the l.o. And then the applicant may or may not decide they found better rates, or are going too look elsewhere, etc. So these are applications approved, but not accepted.

You may call it that, but that doesn't meet the Reg C definition. HMDA says ALL underwriting and creditworthiness conditions are satisfied to call it "approved". That means full verification of everything related to the applicant. It sounds to me like you are making a "conditional approval", but they couldn't be fully approved. For instance, you need an appraisal to ensure they meet the LTV requirements.

Refer to the Commentary to §1003.4(a)(8)(i)#3.

Ahhh, I see.