Is an Application for an Assumption HMDA reportable - this is the scenario in which the application does not result in the written agreement (i.e. denied, withdrawn, etc.)? I can't find this clearly stated in the regulation.

See the flow charts in Appendix E in the 2021 HMDA GIR.

Here is the debate we are having. Appendix E states - Credit granted pursuant to a new debt obligation or is the transaction an assumption?

and guidance also defines an assumption
For purposes of Regulation C, an assumption is a transaction in which an institution enters into a written agreement accepting a new borrower in place of an existing borrower as the obligor on an existing debt obligation.

An application for an assumption (that is denied or withdrawn) does not advance to the point in which a written agreement is accepted. Credit is not granted (following Appendix E). A few in the group say this is therefore not reportable. A few others state that this is only defining that an assumption is a credit transaction and therefore an application for an assumption is reportable.

Reportable?

A few others state that this is only defining that an assumption is a credit transaction and therefore an application for an assumption is reportable.

I agree with this group. I'm not sure how an application for an assumption would not be reportable. An assumption is an extension of credit under Reg. C and would be a covered loan request. Reg. C defines an application as an oral or written request for a covered loan. I don't see any exclusions in 1003.3(c) that would exclude reporting a request for this extension of credit request due to the request not being granted.

Consenting or opposing views welcomed.

FWIW, i agree with Dan.