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#2262569 - 11/16/21 08:32 PM ANA or denial
complyorelse Offline
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Joined: Nov 2007
Posts: 442
U.S.
Applicant was approved for a loan, all closing requirements met, and two days before closing the applicant requests a change in terms. We could not approve the requested change but were still willing to move forward with what had been approved. Applicant did not want to move forward. Do we report as ANA or is it a denial? Or is it both - ANA for HMDA and denial needing an AAN for Reg B?

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#2262570 - 11/16/21 09:03 PM Re: ANA or denial complyorelse
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,965
Bloomington, IN
Applicant amended their credit request - you denied the amendment and they did not accept your counter to continue with the original terms. IMO it's a denial.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2262575 - 11/16/21 09:20 PM Re: ANA or denial complyorelse
Inherent_Risk Offline
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Joined: Jan 2017
Posts: 408
That's how I'd treat it as well.

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#2262581 - 11/16/21 10:26 PM Re: ANA or denial complyorelse
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,553
On the Net
Dan laid it out well. The fact that they were approved initially but not based on their modified request for the loan doesn't change that. They didn't request a second loan, and the bank denied what was on the table/request.
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#2262590 - 11/17/21 01:05 PM Re: ANA or denial complyorelse
complyorelse Offline
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Joined: Nov 2007
Posts: 442
U.S.
Thanks everyone for the feedback.

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