Are we handling the following situation correctly? We had an application for a HELOC where we needed the lien on title to be released prior to making the loan. We are more than 30 days past application, the lien has still not been released, and we haven't made a loan. Today, the loan officer is considering this an approved but not accepted application for HMDA purposes. Should we be sending out an adverse action notice?

Was an approval letter issued subject to the lien being released?

Yes, they sent a contingent approval letter.