Long day.......scenario I've never encountered.

Our HMDA-reportable application is ready for closing. But the applicant indicated "he's not quite ready". Now he is not returning phone calls. Is this Approved-but-not-accepted? He has never actually stated "I don't want this loan" (expressly withdrawn).

Help appreciated!

If the borrower doesn't respond within the stated timeframe, you can consider it not accepted:

3. Action taken—application approved but not accepted. A financial institution reports application approved but not accepted if the financial institution made a credit decision approving the application before closing or account opening, subject solely to outstanding conditions that are customary commitment or closing conditions, but the applicant or the party that initially received the application fails to respond to the financial institution's approval within the specified time, or the closed-end mortgage loan was not otherwise consummated or the account was not otherwise opened. See comment 4(a)(8)(i)-13.

I'd mail something with a drop dead date in it before I went ahead and closed this. You can tie it to the expiration of the credit docs, ie: if you don't close this by....., we will close the file. Overkill, maybe but I believe in CYA.

If they are not responding to phone calls we would close the file and report it as approved but not accepted and be done with it.

If you don't want to send a letter, make one last call and in your message tell the applicant he has until [DATE] to respond. Document the call, close the file as "approved that accepted" if there's no response, and move on to the next item on your list.