This is probably a no brainer, but we're running into an issue of (possible) misunderstanding. In the event we have a loan file where it was declined before a CD ever went out and the borrower didn't pay any discount points nor did the lender give any credits, (I believe) per the Small Entity Compliance Guide (SECG), we need to put N/A in that field. After reviewing the Filing Instructions Guide (FIG), it states if there weren't any discount points or lender credits you would leave it blank, without mentioning if a loan's disposition would change that. Am I reading the SECG correctly by putting in N/A or do we follow the FIG?

Look at V675 from the FIG:

An invalid Discount Points was reported. Please
review the information below and update your file
accordingly.
1) Discount Points must be a number greater than 0,
blank, Exempt, or NA.
2) If Reverse Mortgage equals 1, then Discount
Points must be NA or Exempt.
3) If Open-End Line of Credit equals 1, then Discount
Points must be NA or Exempt.
4) If Business or Commercial Purpose equals 1, then
Discount Points must be NA or Exempt.
5) If Action Taken equals 2, 3, 4, 5, 7, or 8, then
Discount Points must be NA or Exempt.

The following are the instructions I placed on our data input forms.

Total Discount Points
(Enter the total discounts points paid to reduce the interest rate. The figure is disclosed on Line A.01 of the Closing Cost Details page of the CD.)

______________________ (Enter the total dollar and cents, i.e. $3,456.89 would be entered as 3456.89. If no discount points were paid leave blank.)

Enter NA if:
1. The loan is not subject to the ATR requirements of Reg. Z
2. Open end lines of credit (HELOCs)
3. Reverse mortgages
4. Loans primarily for business or commercial purposes
5. Purchased loans (loans purchased by the bank)
(If Action Taken equals 2, 3, 4, 5, 7, or 8 then the Discount Points must be NA. See page 1 for action taken.)

Lender Credits.
(Enter the disclosed lender credits in the second row under Line J of the Closing Cost Details page of the CD. Tolerance cures are not lender credits for this purpose.)

_____________________ (Enter the total dollar and cents, i.e. $3,456.89 would be entered as 3456.89. If there are no lender credits leave blank.)

Enter NA if:
1. The loan is not subject to the ATR requirements of Reg. Z
2. Open end lines of credit (HELOCs)
3. Reverse mortgages
4. Loans primarily for business or commercial purposes
5. Purchased loans (loans purchased by the bank)
(If Action Taken equals 2, 3, 4, 5, 7, or 8 then the Lender Credits must be NA. See page 1 for action taken.)

Thank you both for the input!