Okay. You will need to know who did the underwriting and made the decision to deny the loan. It sounds like this is probably the investor, but I really don't have enough information to know for sure. The way the rule is written, if a creditor mad a credit decision to deny the application, it is required to report the application on its LAR.
The commentary explains this:
"ii. In the case of an application for a covered loan that did not result in an origination, a financial institution reports the action it took on that application if it made a credit decision on the application or was reviewing the application when the application was withdrawn or closed for incompleteness. It is not relevant whether the financial institution received the application from the applicant or from another institution, such as a broker, or whether another financial institution also reviewed and reported an action taken on the same application."
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.www.compliancecohort.com