I want to make sure I understand this section of Regulation C. If we issue a preapproval letter so that the applicant can shop for a new home, but then the application is withdrawn by the applicant without a particular home being selected, would that application be HMDA reportable? I think it would be, but I've seen some training materials that indicate a property must have been selected even though the address hasn't been made known to us. I think we'd report the address as NA.
Here's what Reg C says in Comment 4(a)(9)(i)-3:
3. Property address—not applicable. A financial institution complies with § 1003.4(a)(9)(i) by reporting that the requirement is not applicable if the property address of the property securing the covered loan is not known. For example, if the property did not have a property address at closing or if the applicant did not provide the property address of the property to the financial institution before the application was denied, withdrawn, or closed for incompleteness, the financial institution complies with § 1003.4(a)(9)(i) by reporting that the requirement is not applicable.