We recently discovered some applications received in 2020 where the loan officer failed to take action. The applications were not "statused" properly within the LOS and, therefore, were missed for HMDA reporting. The loan officer supposedly attempted contact with the applicant after taking the application, but never received any response. The loan officer didn't send a notice of incompleteness or a denial. The loan officer wants to call them "withdrawn" due to no response. We can resubmit the 2020 LAR and include them, but we don't know how to code them since they weren't withdrawn, denied, or closed for incompleteness. Should we deny now in 2021 for incompleteness and send an (untimely) AAN and report on the 2021 LAR?

We have procedures and they weren't followed. We are providing refresher training. The pipeline is being monitored more closely. However, I can't change what wasn't done and am at a loss on how to handle these applications. Any thoughts?

Were they incomplete applications or was there enough information to decision the loan? "Withdrawn" is off the table, as only the applicant can expressly withdraw.

I'm going to assume (since the LO was trying to contact them) that these were 'incomplete' in some fashion. There's no great answer here, but i think (if the facts i'm assuming are correct) i'd send out very late AANs and report them on your 2021 LAR.

Honestly, that's something that we have been struggling with. The LO obtained enough information to pull credit and know we could move forward with the request (no reason to deny based on credit). The LO was trying to contact the applicants to get additional information and documentation to move the file to processing and underwriting.

That's what i assumed you meant....if the LO was needing income verification, etc. from the applicants and didn't receive it, i would assume that would be your denial reason (incomplete application).