Hi, I know I asked this back in 2017 or 2018 but cannot find my archives...

If you have a file that was withdrawn as an ANA within 3 business days of application, and therefore no TRID docs were produced (therefore no APR calculated in file)...how do you report the HMDA Rate Spread? Are you allowed to report it as NA?

Typically on an ANA file, the TRID docs (LE) were issued, so we rely on the APR from the most recent TRID doc in file to calculate the Rate Spread for HMDA reporting. Since that TRID doc doesn't exist here, we cannot calculate the Rate Spread.

Any suggestions?

We report NA if there is no Reg Z disclosure required.

"For transactions subject to Regulation C for which no disclosures under Regulation Z are required, a financial institution complies with § 1003.4(a)(12)(i) by reporting that the requirement is not applicable."
We shoved them under this provision as no disclosures are required under Reg Z for a transaction denied or withdrawn within 3 days. It doesn't fit nicely, but it fits better than anything else.

When you say "ANA", are you referring to an approved not accepted file? If so then how would you have an approved not accepted in your situation? You can only have an approved not accepted when all underwriting conditions have been satisfied, so just wondering how this happens in your situation. Also, if the file was withdrawn or denied the rate spread is not reported for HMDA,

Here's what Inherent_Risk is referring to:

In the case of an application approved but not accepted or a preapproval request that was approved but not accepted, §1003.4(a)(12) requires a financial institution to report the applicable rate spread. [Commentary to §1003.4(a)(12) #8 ] Utilize the APR disclosed on the last set of disclosures provided. If no disclosures were provided, report N/A. [Commentary to §1003.4(a)(12) #8]

However, I agree wit comply1. ANA means the applicants have been fully "vetted" - all verifications have been received and they are a "go". The OP said "If you have a file that was withdrawn as an ANA within 3 business days of application . . ." I don't know how that is possible.