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#2245450 - 11/12/20 06:53 PM incomplete app and withdrawal
laf0915 Offline
100 Club
Joined: May 2006
Posts: 236
I am not quite sure how to handle this situation. We had a customer inquire about a refinance loan. The loan officer started an application via electronic application and when he got to the section for quoting rates, the customer decided that the rate wasn't low enough to justify refinancing. At this point, credit had already been pulled. The only piece of information that we did not have at this point was income. Application was not submitted as customer did not wish to proceed. Do we just provide a copy of the credit score disclosure and notice to home loan applicant and document the situation via a memo. Do we have to send any sort of adverse action notice? I also assume it would not be HMDA reportable since we didn't get income or any monitoring information?

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#2245452 - 11/12/20 06:57 PM Re: incomplete app and withdrawal laf0915
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
No adverse action was taken so 1002.9 does not apply.

You do have to provide the FCRA Section 609(f) disclosures.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2245454 - 11/12/20 07:03 PM Re: incomplete app and withdrawal laf0915
laf0915 Offline
100 Club
Joined: May 2006
Posts: 236
Does it need to be reportable for hmda as a withdrawn application or not reportable at all?

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#2245459 - 11/12/20 07:38 PM Re: incomplete app and withdrawal laf0915
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
If it's a covered application it will need to be reported as a withdrawal.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2245460 - 11/12/20 07:58 PM Re: incomplete app and withdrawal laf0915
laf0915 Offline
100 Club
Joined: May 2006
Posts: 236
Would I then report income as na and also not provided for monitoring information? Thanks for your help - it is appreciated.

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#2245526 - 11/13/20 10:50 PM Re: incomplete app and withdrawal laf0915
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
First you have to determine if you have a covered application. Most likely you do for HMDA but not knowing the details I can't say for sure.

Go to the 2020 HMDA GIR and use withdrawn as the search term. You will find the guidance you need for reporting the information you asked about. The income question is addressed on page I-44.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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