We have made the decision to treat the receipt of ALIENS as the trigger for an application for TRID, REG B and HMDA.

I cannot grasp if the following scenario would be HMDA reportable:

We do not have ALIENS, but in taking an application (or discussing a loan request with an applicant), the MLO communicates that we will not make the loan for whatever reason (which they are told not to do). We have adverse action under Reg B and will send an AAN. But since we do not have ALIENS, would this be considered HMDA reportable? Or for HMDA purposes, can we truly discern an application only when we have ALIENS if that is our process? I know HMDA covers withdrawals, declines, etc., but must we have ALIENS first?

I'm stuck in that if we send an AAN under Reg B, does that also make it HMDA reportable?

Thank you!!

I think I answered my question. In my scenario above, we would be required to report the application as Application Denied on the LAR. If we are missing demographic information (race, ethnicity, sex, and/or age), we use the code for "not provided" or the MLO provides it based on visual observation. Is that correct? I welcome any other thoughts on this - thank you!!

Application denied. A financial institution reports that the application was denied if it made a credit decision denying the application before the applicant withdraws the application or the file is closed for incompleteness. Comment 4(a)(8)(i)-4. For the action taken date, the financial institution reports either the date the action was taken or the date the notice was sent to the applicant. Comment 4(a)(8)(ii)-2.

I'd use a caveat for prequals (lacking a subject property address):

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.