Good morning!

We use decisioning software for our consumer loans. For non-mortgage loans the loans are not underwritten manually; however for mortgage loans there is an initial 'approval' or 'denial' and all loans are manually underwritten. If the loan receives an initial approval; however the customer withdraws before the manual underwriting process - in your opinion would this be a withdrawal or an 'approved not accepted' for HMDA purposes?

If they are not formally approved barring normal closing conditions, then the loan has not been approved.

Thank you Randy. I was leaning that way, but wanted to bounce it off of someone else too.

Now - to get everyone to understand what 'expressly withdrawn by applicant' means.

What? You mean " we never heard from them again" doesn't work

Ha!

Skittles, FWIW we have an automated application system that approves the application based on the stated information, but then the underwriter is responsible for verifying the information and will then document a final decision date once all verifications and underwriting conditions are cleared. The applicant has until that final decision date to withdraw the application. As long as the process is clear to examiners you should have no issues.