Looking for opinions on the following scenario:

Application for a HMDA reportable loan submitted electronically. LO contacts applicant to discuss application and during that discussion the borrower decides to change the loan amount requested. LO did not effectively deny the application by telling the applicant they did not qualify for the original loan amount requested.

If the application is subsequently denied by underwriting, closed for incompleteness, or is withdrawn by the applicant, what loan amount is reported for HMDA?

In §1003.4(a)(7)-3 Reg. C says the "financial institution reports the amount for which the applicant applied." Does that mean the amount for which the applicant ORIGINALLY applied when they submitted the application electronically? Or should we consider the amount for which the applicant applied to be the changed loan amount?

I would report the amended amount. Applications aren't static, never-changing things....they can and often are amended at the applicant's request.

I agree. The amended amount is the amount they applied for.

You wouldn't tell them they have now withdrawn an application for the first amount and need to reapply for the new amount. I agree, its the same request. I'd also take the question as a teachable moment and ensure the bank as a whole does this the same way procedurally.

Thank you everyone. I heard contrary opinions so just wanted to confirm others agreed with me.