I think I'm losing my mind but for AANs, our prior Compliance Director told everyone that if the bank has already performed underwriting on a loan request and the applicant then decides not to proceed, that this would then be a denial. That a true withdrawal is "prior" to underwriting. Is that correct?

a true withdrawal is "prior" to underwriting. Is that correct?

Yes. Once a credit decision has been made you cannot treat the application as a withdrawal.

Whether it would be a denial would be determined by the credit decision made. It could very well be an approved but not accepted.

Thank you for clarifying for me and I will pass this information along to our lenders.

I still have nightmares about this. OCC exam, pre-work for CRA. Examiner disagrees with a HMDA entry that was "withdrawn" and says a credit decision had been made. "How do you know this based on what's on the loan app" I asked. There was a note from the lender on the top of a worksheet that could be seen only when removed from the file folder (the nails at the top hid it), "tell him it's approved but at X%. He won't accept that though." Sure enough he didn't and according to that branch, it was "withdrawn" but that branch had fallen from the HMDA tree.

Made me start looking at all the little notes that used t be added in paper files.

"Yes. Once a credit decision has been made you cannot treat the application as a withdrawal.
Whether it would be a denial would be determined by the credit decision made. It could very well be an approved but not accepted."

I think the easy way of looking at actions is like throwing 5 darts at a dartboard.
The first one to hit sticks.