I think a lot of people on here would disagree, but I would not consider those applications. I think you could either call them prequalifications (see below) or simply say they are not made in accordance with your procedures (which would be a harder argument). Getting compliant HMDA data would be nearly impossible in these cases.
1003.2(b) - Comment 2. Prequalification. A prequalification request is a request by a prospective loan applicant (other than a request for preapproval) for a preliminary determination on whether the prospective loan applicant would likely qualify for credit under an institution's standards, or for a determination on the amount of credit for which the prospective applicant would likely qualify. Some institutions evaluate prequalification requests through a procedure that is separate from the institution's normal loan application process; others use the same process. In either case, Regulation C does not require an institution to report prequalification requests on the loan/application register, even though these requests may constitute applications under Regulation B for purposes of adverse action notices.