For a denied or withdrawn application that had a definite term, you list the term that would have applied. The only time you list NA for the loan term is if an application does not have a definite term, such as a reverse mortgage.
From Regulation C:
"(25) The scheduled number of months after which the legal obligation will mature or terminate or would have matured or terminated."
From the CFPB reporting reference chart:
"Enter “NA†for covered loan or application without a definite term, such as a reverse mortgage, Comment 4(a)(25)-5."
From the Commentary to Regulation C:
5. Loan or application without a definite term. For a covered loan or application without a definite term, such as a reverse mortgage, a financial institution complies with § 1003.4(a)(25) by reporting that the requirement is not applicable.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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