We received an application for a consumer construction to permanent loan. We do not offer this type of credit. We only offer construction only loans to consumers. The lender sent a Adverse Action Notice/Counteroffer and countered a construction only product. The applicant did not accept.
Do we report the original application on our HMDA LAR? I am thinking no since we do not offer that type of credit/product that was requested. Additionally, we would have no terms to report such as loan term and introductory period, etc.
Always learning something new...