How do you handle reporting a loan that was denied where we had not yet obtained a property value? It was a refinance application and it was denied before we even completed an AVM. It appears that the commentary would supporting listing n/a in this case as well.

If a loan is denied because we don't offer it (like a refi on a manufactured home) and therefore we didn't obtain an AVM, is this an acceptable time to use n/a for the property value since it wasn't a consideration of the credit decision?

The commentary I am pulling from is 1003.4(a)(28)--3 and 4.

Correct, NA.

Enter “NA” for:
â–ª Transactions for which no credit decision was made (e.g., files closed for incompleteness, or if an application was withdrawn before a credit decision was made), Comment 4(a)(28)-3;
â–ª Transactions for which the credit decision was made without relying on property value, Comment 4(a)(28)-4

https://www.consumerfinance.gov/documents/8129/cfpb_2020-reportable-hmda-data.pdf

Don't you ask the customer for an estimated value when you take a loan application?

It is not a required field on our online applications.