I have 2 applications for a refinance- one for a 1st lien and one for a 2nd lien on same property. During the application process, the 2nd lien was removed and "unlinked" and the amount was added to the first. The 2nd lien refi was NOT expressly withdrawn by the applicant, this was all done internally. Is the 2nd lien loan reportable for HMDA or is this just a dead file?

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How is it that the bank departed from what the customer requested and combined the two requests into one? Did the customer agree to that change (applicants sometimes ask for a separate second-lien loan they can pay down and out sooner than the first-lien loan)?

Did the bank tell the applicant it would be able to make the first-lien loan for the combined amount, and the applicant agreed?