Hi all
We have a signed application from the borrowers for a loan amount of $100,000. At some point, there was a change in the loan amount to $110,000, and we have a signed COC LE showing the change. Then the customer withdrew their application(before a credit decision was made). Does the COC LE constitute a change in the amount "applied for" for HMDA? which loan amount do we use for reporting?

AND- same question for a denial (same scenario, except we denied the file in UW)- do we HMDA report the new loan amount that we denied the loan at or the old one on the signed application?

The rule is pretty clear that you use the "amount applied for, but I guess my question is, does a COC LE constitute a change in the "amount applied for" for HMDA purposes?

Rule states: Covered loan amount - application approved but not accepted or preapproval request approved but not accepted. A financial institution reports the covered loan amount that was approved. Covered loan amount - preapproval request denied, application denied, closed for incompleteness or withdrawn. For a preapproval request that was denied, and for an application that was denied, closed for incompleteness, or withdrawn, a financial institution reports the amount for which the applicant applied.

any help is appreciated! thanks

Did the customer request the change in the loan amount?

Yes- but give me an example of when they don't request it? I feel it would be abnormal for us to change a loan amount on someone when they didn't request it

I think it would be odd too....i think the point is: the file should be documented to show WHY the loan amount went up.

I've seen situations where the DTI is too high for the amount requested, but the bank counters with an increase to pay off additional debt. That conversation could be had by a banker prior to sending the file to an underwriter.

Ok so whether they did or did not request it, which loan amount would you report in both situations?

It depends on whether they requested it or not. If they requested the change, then most would consider that an amended application and go with that amount. If they didn't request the change, it would most likely be a counter-offer and you would probably go with the original amount as it would appear they didn't accept the counter offer (as the loan didn't close).

And if it were a counter-offer, you're most likely looking at a denial rather than withdrawal. This is how we would handle it:

If they applied for $100,000, requested to increase the amount to $110,000, then later withdrew prior to a decision- this would be coded as withdrawn for $110,000.

If they applied for $100,000, the bank for whatever reason tells the applicant "$100,000 isn't going to work, but we can do $110,000" then you have denied their original application for $100,000 and countered with $110,000. They later "withdraw" and the loan does not close (they didn't accept your counter offer)- this would be coded as denied for $100,000 because you told them you couldn't do the $100,000 loan amount.

makes sense. thank you!

thank you!