Not sure how you can say the loan is approved if you "...do not have an appraisal, we didn't get that far". Did you communicate approval to the borrowers or not?

From this BOL post So send the denial and report it as such too.

I agree that the applicants can't be approved [final approval based on "Underwriting or Creditworthiness Conditions" as defined in the Commentary to §1003.4(a)(8)(i) #13(iii)]. Therefore, it can't be ANA for HMDA.

Thank you.