We are a small filer, and do not have to report the denial reasons on denied loan. So for a loan that was originated, what code do we put on reasons for denial? 10 (NA) or 1111 (exempt)?

I would think that the action taken is "Originated" then the denial reason would be "NA". ?? But that sounds too easy. haha

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 denial—not applicable. A financial institution complies with § 1003.4(a)(16) by reporting that the requirement is not applicable if the action taken on the application, pursuant to § 1003.4(a)(8), is not a denial. For example, a financial institution complies with § 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financial institution, or the application or preapproval request was approved but not accepted, or the application was withdrawn before a credit decision was made, or the file was closed for incompleteness."

You report "1111" because it is a numeric field. If you report "NA" you are actually reporting data, not saying you are exempt.

Let me add to my previous post:
Large filers and small filers that wish to voluntary provide the reasons for denial, would report "NA" for loans that are originated.

But he said the loans was "originated".

Correct, but Dave makes a good point of clarification for others who may be reading this thread with a slightly different situation. The partial exemption has caused quite a bit of confusion, and this is one of those areas where extra clarification is beneficial.

I understand the loan was originated. If you report "NA", then you are reporting you didn't deny it. If you are a small filer and wish to state "this is exempt from reporting" then the proper code is "1111". That's my point.

Ok makes sense. Thanks!!!