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#2264978 - 01/21/22 02:58 PM Reportable? What Action Taken?
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Joined: Nov 2008
Posts: 1,055
In the mountains
We received an application with the 6 pieces of information for TRID LE disclosure on 11.18.21 and the applicant provided their financial information documents. On 11.19.21, the applicant emailed stating that the home listed on the application was under contract, so instead they wanted a prequalification letter for a future purchase. Then on 11.23.21, the applicant stated that they are putting in a back-up offer on the property that is under contract, so they wanted to continue to move forward with the application. Later that day, the applicant lets the bank know that they property has in fact sold to the other buyer that put in the first offer. The applicant at this point wants to continue with a prequalification. A cash flow was ordered and on 12.22.21, the applicant was sent a combined decline counteroffer because they were looking to prequalify for $765,000, but based on the cash flow they would only qualify for $475,000.

Do we report this as a withdrawn application for $765,000 based on the original request that fell through since the home was sold to someone else and report that property address?
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#2264989 - 01/21/22 04:28 PM Re: Reportable? What Action Taken? Likes to Comply
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 46,765
Bloomington, IN
The 6 piece information for TRID does not necessarily constitute an application for HMDA.

the applicant emailed stating that the home listed on the application was under contract,so instead they wanted a prequalification letter for a future purchase.

You don't state when this took place in the application process.

Do we report this as a withdrawn application for $765,000 based on the original request that fell through since the home was sold to someone else and report that property address?

Based on the information provided that's what I would advise doing. I'm not sure how you could argue the original credit request was not a withdrawn application subject to HMDA.
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The opinions expressed are mine and they are not to be taken as legal advice.

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