Situation: customer submitted offer to purchase a house, at the same time applying for the loan under the assumption their offer would be accepted. However, it was not, so they WD their application.

Would you consider this a pre-approval request? And, since we do not have an official pre-approval program, it would not be reportable?

Doesn't sound like a pre-approval to me, since it sounds like they submitted an application with a property address.

(But i should probably add--my bank doesn't have a preapproval program.....so the preapproval part of HMDA isn't in my wheelhouse.)

Ditto raitchjay. If you had a property address and an application, it wasn't a pre-approval.

I fully agree. Prequal/preapproval means no house yet.

So, even though they didn't have a signed/executed contract? To me, my thought process is: no signed/executed contract = no house. To me, the customer was counting their chickens before they hatched. But, at the same time, I do see y'alls point as well.

Yes, that is how most of us view it. Once they give you an address, contract or not, it would no longer be a preapproval - as a preapproval is specifically for shopping for a house.

You can't condition delivery of the LE on receipt of a purchase contract either.

Bottom line: Whether or not you ever receive a copy of the purchase contract does not impact disclosure and reporting requirements for any of the regulations. While that might be a piece of documentation that you require on a purchase transaction, it is just that, a piece of documentation.

Let me say it another way: The purchase agreement/contract is a verification document. You can ask for it, but not require it for TRID. For HMDA, the rule is "no house identified".

If you review §1003.2(b)(2)(i), you'll see that preapprovals discuss "the identification of a suitable property" as an acceptable condition. There are limited conditions you can have. A purchase agreement is not one of them and the identification of a property makes it no longer a preapproval.