We have a preapproval program that counts preapproval applications as applications under HMDA. We use the date they applied for the preapproval as the App date in HMDA.

Since Demographic Information is to be collected at application, does that mean that we collect this at preapproval application?

To go a step further: Do we have to read the DI HMDA script to applicants if we take a preapproval application over the phone?

I'm thinking yes, but I can't find confirmation. Any help would be appreciated, thanks!

Preapprovals are reportable if they are denied, approved not accepted or converted to a full application. Why would you not collect DI?

Good point HMDAGal. That would be the logical thought, but some things in HMDA are not logical, so I just wanted to double check. But you are right, it is supposed to be collected at application, and a preapproval is an application.

I had an over-think moment after I saw the V613 error:

If there was a preapproval accepted and the application moved on to where an appraisal was pulled and/or other assessments were made and the financial institution had to deny the application, you would report action taken as code 3 denied, but the preapproval request code cannot be "1. Preapproval was requested". V613 Error

So if you have a 3.Denied application (not 7. Preapproval request denied, of 8.preapproval approved not accepted) you would have HMDA data that states there was no preapproval, but you would use the application date from the preapproval request and DI collected on the preapproval request.

Thank you!

If a preapproval was requested you would also report code 1 for action types 1 and 2.