Hitting a wall on this one: customer applied for a VA IRRRL loan when we were not offering the product. Would this be a reportable application?

From a Reg B standpoint it isn't a denial since we were not participating in the program, but now I am second guessing myself if I have carried that thought too far in making it non-HMDA reportable as well, since we don't have a denial to report.

I think there is a strong case that you don't need to report this application, given the definition in 1003.2(b)(1):



If you weren't in the program at the time, you would not have procedures used for the type of credit requested.

Thank you for affirming for me. The more I got into my head on this one the more I was twisting myself around and second guessing our work. Thanks!