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#2256297 - 07/04/21 08:51 PM How to Report Change in Loan Program
hodea Offline
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Joined: May 2014
Posts: 2
I have a loan that started initially as a VA purchase. The underwriter suspended the loan due to not enough eligibility. The borrower requested to change to a conventional loan. A revised LE/COC was prepared and the file was underwritten as a conventional and a conditional approval given. The borrower now wishes to withdraw and not continue with the file.

How would I report this for HMDA & Reg B? No formal counter offer was given or accepted, just the borrower request to change to conventional.

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#2256302 - 07/06/21 01:05 PM Re: How to Report Change in Loan Program hodea
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 76,929
Galveston, TX
A counteroffer does not have to be formal. If I understand, the applicant asked you if they would qualify for a different product, you approved them, so IMHO is is approved not accepted for HMDA purposes. Since it does not appear they expressly accepted the counteroffer, then under Regulation B, you owe them a AAN for the VA loan.
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#2256320 - 07/06/21 04:10 PM Re: How to Report Change in Loan Program hodea
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,364
Bloomington, IN
If any of the conditions were creditworthiness conditions then I would have to opiine you have a withdrawal.

If they were customary closing conditions then I would agree with approved but not accepted.

In either case I agree you have adverse action under Reg. B.
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#2256408 - 07/08/21 01:02 AM Re: How to Report Change in Loan Program hodea
hodea Offline
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Joined: May 2014
Posts: 2
Thank you both

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