I was having similar thoughts.
You have a couple of things going on here. You stated: " believe we need to go through each file and determine the date it was either, Denied, Approved not accepted, or withdrawn according to HMDA definitions".
1) That is true and if you do that, then you will know the volume of loans not reported for previous years in order to make the call on whether to refile your HMDA LAR or not. (HMDA Violation)
2), If any of these files were denied without an adverse action notice being sent, then adverse action notice should be generated and sent to the borrowers. (Reg B Violation)
3) If these applications were never dispositioned, then you are left with the task to figure out what happened and disposition them. (HMDA and Reg B Violation) Likely, they were all actually denied for incompleteness.
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