Have a RE loan application for a bridge loan in late 2021.The application has the amount and property address being purchased. Long story short the house they were wanting to purchase someone else beat their bid. Customer decided to purchase another home for a larger amount in 2022 so customer should have filled out a new application at this time as the first application was no longer valid. Correct?

How can we answer that question? Was the previous application expressly withdrawn by the customer?

The previous application was not withdrawn by the customer nothing is noted on the application about withdrawing. I would think you would need a new application.

I would think you would need a new application.

Why? Applications do not just disappear. They have to be dispositioned in some manner. Either the applicant withdrew the application, or you closed or denied the application for incompleteness. Otherwise, the application remains active.

How did you report the 2021 application for HMDA purposes?

Not a HMDA bank

Would you typically change the property and use the existing app, or "retire" that app in some way and get a new one? In my mind, if you have an app outstanding from 2021 there better be some really detailed notes as to why there hasn't been a credit decision made.