If the borrower truly initiated contact to the bank and withdrew, I would call it a withdrawn loan for Reg B purposes. However, I have seen instances where a loan officer "steered" a customer to withdraw due to this type of information. If that was the case, it would be a denial. Just make sure you document your file clearly as to what actually happened.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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