It should be reported as exempt (i.e. 1111) as NA is supposed to be used when the application is NOT a denial, meaning that listing NA for a denied loan would be incorrect.
From the commentary:
"4. Reason for denialâ€”not applicable. A financial institution complies with Â§ 1003.4(a)(16) by reporting that the requirement is not applicable if the action taken on the application, pursuant to Â§ 1003.4(a)(8), is not a denial. For example, a financial institution complies with Â§ 1003.4(a)(16) by reporting that the requirement is not applicable if the loan is originated or purchased by the financial institution, or the application or preapproval request was approved but not accepted, or the application was withdrawn before a credit decision was made, or the file was closed for incompleteness."
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.www.compliancecohort.com