Hello,

In scenarios where there is an approval with outstanding credit conditions, in most instances it is only the Verbal Verification of Employment and loan fails to originate due to either title issues or commitment expired or borrower non responsive - borrower did not expressly withdraw. In these cases, it is coded as denied for HMDA but from a Reg B. perspective is an adverse action notice required to be sent?

If yes, what would be the denial reasons in these scenarios? There is not a credit issue for which to issue an Adverse Action Notice under Reg B. but for HMDA need to show as denied and enter a reason. Thanks!!

Sounds like you've got Approved but not Accepted on a couple of those scenarios which would not be a denial for either Reg.

In scenarios where there is an approval with outstanding credit conditions,

If credit conditions are not met you have a denial for both HMDA and Reg. B.

Dan's right. HMDA does not recognize "conditional" approvals. You say "there is an approval with outstanding credit conditions. . ." If they are property conditions, for HMDA that's not an Approval or an Approved Not Accepted.

If there are title issues - you deny it for that reason. If the applicant(s) was fully approved (met ALL Underwriting or Creditworthiness Conditions), then it would be ANA for HMDA.
If the borrower is non responsive, for Reg B you can either deny it because you haven't heard from them or send a Notice of Incompleteness. For HMDA, again, it depends on whether the applicant(s) have been fully approved. If so, you would call it ANA. If not, you would deny it or called it closed for incompleteness (depending on how you handled it for Reg B).

Thanks David for the response. In instances where there is only the Verbal Verification of Employment outstanding and loan fails to close due to title issues or unresponsive borrower (therefore no expressly withdrawn), I know for HMDA we report it as denied due to there being an outstanding credit condition (VVOE), what would be the denial reasons and is an AAN required for Reg B? That is kinda where I am stumped. Thanks again!

I think your reaching by using the VVOE, which cannot be done till the last minute, as your reason.
Each file is different.
If a title issue is keeping you from closing, that's the denial reason, not the VVOE.
For the unresonsive borrower, did you send an incomplete notice? If so, then the HMDA code would be closed for incompleteness.