How is everyone reporting apps that have multiple 9-Other denial reasons on the HMDA LAR? Examples include the following:
1) UNABLE TO FINANCE FOR TERMS OR CONDITIONS REQUESTED
2) OUT OF BANK'S LENDING AREA
3) PROPERTY OWNERSHIP AND OTHER TITLE ISSUES

What if all 3 were denial reasons? Do you report just the one that is most general, or do you somehow combine all 3 in the TEXT box? As you know LOS's usually only have the ability to report 1 9-Other reason via an automated process. Thanks for you incite.

1. What caused the applicant to be denied for the terms and conditions requested?

2. Column BP - code 9 - Column BS - Out of Area

3. Column BQ - reason code 4

1. This 9-Other reason is usually for things specific to our bank or the LOB guidelines
2. You seemed to agree with this one.
3. 4-Collateral is related to insufficient collateral type or value, so anything related to owners on title or the lack thereof is more appropriately reported under our specific 9-Other reason. The same is true for items like the 1st lien already being a HE loan (especially being in Texas), so it was required that it be paid off when getting another HE loan (sometimes not disclosed upfront and discovered later). We noticed with the scope of our OCC exams, especially now when their focusing on addressing appraisal disparities/bias, we need the 4-Collateral denial reason to be purely the regulatory definition.

Please note my question was more specific to how one would report if they had multiple 9-Other reasons. What is considered acceptable? I know you are trying to convert our reasons to other codes, but regardless of whether or not you rightfully did so, my question would still remain as there are other 9-Other reasons we have (Ex. AMOUNT IS BELOW MINIMUM FOR THIS PRODUCT). Note we don't have many more than this, if any, as I know we are to minimize our usage of the 9-Other reason.