I'm just trying to make sure I'm following what you are saying - thanks for being patient. I found an internal memo (February) from the underwriting department to the lender stating the HELOC was conditionally approved, but the HELOC must be the first and only lien on the subject collateral. It also states the customer must currently own the home free and clear of any liens and that the approval expires March 6. The applicant kept saying he would get the lien cleared but hasn't. Now, the underwriting dept/loan officer want to report this as Approved but not Accepted for HMDA purposes. It seems that we have met the definition for reporting an Application Approved but Not Accepted because this clear title issue is a condition that is a customary commitment or closing condition. However, I don't find anything in writing (Conditional Approval/Notice of Incompleteness) to the customer relating this and a specific timeframe by which they must be completed. If there is no written notice of incompleteness with the lien issue and a required timeframe, wouldn't this be considered a Denial instead and we should send an Adverse Action Notice?