I guess it depends how in depth you want to go with what precise terminology an applicant needs to use to withdraw. It basically sounds like they are no longer interested. I could justify calling this a withdrawal, but, otherwise, I agree it's a denial for incompleteness. Do they really need to exactly use the specific word "withdraw?" If a Bank calls an applicant that they haven't heard from in a couple months and the person says, "I got a loan somewhere else" and then hangs up, is that not a withdrawal?