Lender took app in late August for home purchase, which was approved before the deal fell through in mid-September. The applicant asked lender to keep the file open as he looked for a another property to purchase. Fast forward to December--applicant contacted lender to let him know that he was no longer looking for a home. The action taken seems to be approved not accepted as of the September date, but because the lender held the file, the application was not entered on the LAR by 10/31. Instead, we get the file, showing approved not accepted for 12/15. What is the final action taken and which date should be used?

When the applicant contacted the lender and said I am not going to take the loan, the deal fell through. It appears you have a training opportunity.

When the applicant contacted the lender and said I am not going to take the loan, the deal fell through

100% agree and then if the applicant later found another home you could have reinstated the application using the following guidance for the application date.

3. Application date—reinstated application. If, within the same calendar year, an applicant asks
a financial institution to reinstate a counteroffer that the applicant previously did not accept (or
asks the institution to reconsider an application that was denied, withdrawn, or closed for
incompleteness), the institution may treat that request as the continuation of the earlier
transaction using the same ULI or NULI or as a new transaction with a new ULI or NULI. If the
institution treats the request for reinstatement or reconsideration as a new transaction, it reports
the date of the request as the application date. If the institution does not treat the request for
reinstatement or reconsideration as a new transaction, it reports the original application date.

So approved not accepted for 9/13 and we have a violation because we didn't have it entered on the LAR by 10/31?

Technically correct. I doubt there will be any repercussions, though, unless you develop a pattern or practice of entering applications/loans late. This situation sounds like an isolated case.