This means we could potentially report the same applicants multiple times if we have preapprovals expire too soon and they keep re-doing them.
That would depend how you choose to treat the reinstated applications (within the same calendar year).
Page l-30 in the 2022 A Guide to HMDA Reporting - Getting it Right (referred to as the GIR)
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asks the institution to reconsider an application that was denied, withdrawn, or closed for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.
The opinions expressed are mine and they are not to be taken as legal advice.