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#2208822 - 03/15/19 01:37 PM Withdrawal who wants to resume
AW27 Offline
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Joined: Jan 2017
Posts: 22
I've been doing HMDA for a long time but someone asked me this question the other day and I had to pause bc I wasn't sure...
If a customer withdraws, but then comes back one week later, or two weeks, etc and wants to resume, would you still log the withdraw and then also the origination on your LAR?

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#2208823 - 03/15/19 01:46 PM Re: Withdrawal who wants to resume AW27
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,662
From comment 3 to 1003.4(a)(1)(ii):

"3. Application date—reinstated application. If, within the same calendar year, an applicant asks a financial institution to reinstate a counteroffer that the applicant previously did not accept (or asks the institution to reconsider an application that was denied, withdrawn, or closed for incompleteness), the institution may treat that request as the continuation of the earlier transaction using the same ULI or as a new transaction with a new ULI. If the institution treats the request for reinstatement or reconsideration as a new transaction, it reports the date of the request as the application date. If the institution does not treat the request for reinstatement or reconsideration as a new transaction, it reports the original application date."
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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