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#2272221 - 06/28/22 09:11 PM Reportable loan amount
Jason Ellis Offline
Junior Member
Joined: Jun 2018
Posts: 35
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If the application is subsequently denied by underwriting, closed for incompleteness, or is withdrawn by the applicant, what loan amount is reported for HMDA?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 ยง1003.4(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?

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#2272223 - 06/28/22 09:19 PM Re: Reportable loan amount Jason Ellis
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 8,733
OK
I would report the amended amount. Applications aren't static, never-changing things....they can and often are amended at the applicant's request.
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#2272235 - 06/29/22 12:56 PM Re: Reportable loan amount Jason Ellis
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,769
Bloomington, IN
I agree. The amended amount is the amount they applied for.
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#2272293 - 06/29/22 09:25 PM Re: Reportable loan amount Jason Ellis
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,485
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You wouldn't tell them they have now withdrawn an application for the first amount and need to reapply for the new amount.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.
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#2272314 - 06/30/22 02:27 PM Re: Reportable loan amount Jason Ellis
Jason Ellis Offline
Junior Member
Joined: Jun 2018
Posts: 35
Thank you everyone. I heard contrary opinions so just wanted to confirm others agreed with me.

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