Inherent_Risk: My point is that it's an application. It isn't a completed application. You have a request for credit. I'm not sure how you can say that's not an application. If you hanging you hat on the "made in accordance with procedures" part of the definition in §1993.2(b)(1), I think it's thin ice, but that's not really what this thread is about.
Fiddlesticks: Since you denied it, you can't really go back to them now. The FIG states:
Enter, in numeral form, the age, in years, of the applicant or borrower, or of the first co- applicant or co-borrower, as applicable. Age is calculated, as of the application date, as the number of whole years derived from the date of birth shown on the application form. Or enter the applicable Code from the following:
Code 8888—Not applicable
I would report 8888 as you don't have "date of birth shown on the application form."