Skip to content
BOL Conferences
Learn More - Click Here!

New Reply Thread Options
#2254526 - 05/27/21 05:51 PM How do we handle this for HMDA?
Anonymous
Unregistered

We had a HMDA reportable loan with an app that was submitted twice. The borrower applied online and then went into a branch and applied as well. It wasn't until much later in the process that we realized that there were two applications for the same person.

Are both HMDA reportable? We cancelled the duplicate app, but it wasn't expressly withdrawn by the applicant.

Return to Top Reply Quote Quick Reply Quick Quote
#2254529 - 05/27/21 05:54 PM Re: How do we handle this for HMDA? Anonymous
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 9,108
OK
No, this should only result in one entry on your LAR. I would probably just keep both applications with the file and document what happened.

An "application" isn't the piece of paper (or virtual paper) that an applicant submits....it's the information within it (which can happen verbally too). A redundant resubmission of the same information doesn't (IMHO) create a new "application".
Last edited by raitchjay; 05/27/21 06:03 PM.
_________________________
I'm fixin' to fix that.

Return to Top Reply Quote Quick Reply Quick Quote
#2254566 - 05/27/21 08:41 PM Re: How do we handle this for HMDA? Anonymous
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,754
On the Net
Agreed. This assumes the two requests were the same. Document that and anyone should agree that there was one application for one loan, not multiple loans or multiple properties or liens.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top Reply Quote Quick Reply Quick Quote
Quick Reply:
HTML is disabled
UBBCode is enabled




Moderator:  MagicCity, P*Q, Truffle Royale