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#2209376 - 03/25/19 03:09 PM AUS on pre-qual, then address
MBrownie Offline
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MBrownie
Joined: May 2015
Posts: 96
I have a withdrawn HMDA application. Desktop Underwriter was run while this was a pre-qualification. An address was then received, making the application HMDA reportable. However, customer withdrew before the application was sent for underwriting. Do I report the AUS? Or not since it wasn't a HMDA application when it was run?

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#2209395 - 03/25/19 04:29 PM Re: AUS on pre-qual, then address MBrownie
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
If you "used" DU to evaluate the applicant's, you need to report it. Here's the reg and commentary to support my

Report …the name of the automated underwriting system used by the financial institution to evaluate the application and the result generated by that automated underwriting system. [§1003.4(a)(35)(i)]
Report …the name of the AUS used… to evaluate the application and the result generated by that system, regardless of whether the AUS was used in… the …underwriting process. [Commentary to §1003.4(a)(35) #1(ii)]

I think it would be difficult to argue that you didn't use it if you have it.
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David Dickinson
http://www.bankerscompliance.com

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#2209401 - 03/25/19 04:46 PM Re: AUS on pre-qual, then address MBrownie
MBrownie Offline
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MBrownie
Joined: May 2015
Posts: 96
Thank you David, that makes sense. I was getting caught in the weeds I think. smile

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