Our bank has a documented preapproval program. Recently we have had applications that were submitted as preapprovals; however, before we could review and provide the borrower the preapproval letter the borrower identified a property.

Should these be coded as preapprovals or not?

Unless a decision was made prior to the property being added, this would no longer be a preapproval request.

Page 23 - 2021 GIR

A preapproval request is an application under Regulation C if the request is:
1. For a home purchase loan;
2. Not secured by a multifamily dwelling;
3. Not for an open-end line of credit or for a reverse mortgage; and
4. Reviewed under a preapproval program (see definition of preapproval program
immediately below). 12 CFR 1003.2(b)(2).

We are having confusion on this subject and looking for clarification. We have an application with property TBD that was preapproved with the following conditions:
- no changes in financial or employment status
- fully executed purchase agreement
- satisfactory appraisal
- title committment
- flood zone certificate
- hazard insurance
Also preapproval application had 4 applicants.

Property was identified and purchase agreement provided 1/20/22. Application was subsequently withdrawn because 1st two applicants no longer needed parents to help them to qualify for the loan. New application with just the original 2 applicants was started.

Our question is how do we treat the application with the 4 applicants for HMDA. Is it an approved not accepted? Preapproval withdrawn and thus not reportable? Or do we really have 2 applications - and we treat the application with the TBD address as preapproval withdrawn (not reportable) and then the application with the property address and the 4 applicants as approved not accepted?

Since the property was identified before the 4 applicant application was withdrawn then IMO you have a withdrawn application.