I have some questions regarding the loan amount and what should be reported for HMDA for an Adverse Action loan (withdrawn, incomplete, & denied). This can be confusing in our HMDA loan reviews. We have received some input from our mortgage loan department on what to report for the loan amount when we have not sent disclosures or have sent disclosures out to the borrower. Here are a few things discussed recently. 1 - It was discussed that loans that have not made it to disclosure yet we would revert the loan amount for HMDA to what was originally applied for. 2 – For loans that we have sent out disclosures on but have not made it to Conditional Approval yet, we would revert to the first disclosed loan amount for HMDA. 3 – Loans that have made it to Conditional Approval do we consider the fact that it has been conditionally approved and a CD has gone out to the applicant or not? Do we report the last disclosed amount for the loan that was conditionally approved or not? If we have provided an LE and/or CD to the applicant and the loan is withdrawn, incomplete, or denied does the last disclosed loan amount have any bearing on the loan amount reported for HMDA? I don't feel that everyone is on the same page and need some outside input. I cannot find anything within the regulation (REG C) stating to report the last disclosed loan amount and can only find that we should report the loan amount that was originally applied for. Do we also have to take into consideration TRID requirements for the HMDA reportable loan amount? Sorry for all the questions. Any information you can provide would be great. Please let me know if you need any more information. Thanks.

1. Correct
2. Correct only if the applicant requested the amount applied for on the disclosure, which I assume is the LE.
3. How can you send a CD to an applicant for a conditionally approved loan when you don't know the terms have been accepted?

The loan amount reported in the case of a denial is the original amount applied for.by the applicant. That would include withdrawals and conditionally approved loans where underwriting conditions were not met .

The amount for an Approved but Not Accepted would be the amount approved.

There is a chart in the 2023 GIR beginning on page 68 (PDF page 160) that covers the loan amount or you can refer to 1003.4(a)(7) and its Official Interpretation for the Covered Loan Amount.

(7) The amount of the covered loan or the amount applied for, as applicable.

Thank you so much Dan I appreciate your help. I was asking these questions as this is what our mortgage department is currently doing. Thanks again I will bring this up in our next meeting.

Correct only if the applicant requested the amount applied for on the disclosure, which I assume is the LE.

This is the sticky point. LOs cannot change loan amounts based on what they think the borrower really wants.
The applicant has to request the change in loan amount from what they originally put on the 1003.
In my world, that requires documentation in the form of an email from the applicant, a changed request form properly filled out stating when the borrower requested the change, or something similar.

Thanks TR. I will be sure to mention this in our next meeting as I would agree. We are really struggling right now with validating the loan amounts on our AAs and no supporting documentation in the files for the loan amount originally applied for. We could see several different loan amounts in our review for HMDA. This is why I have two questions out here right now and probably could ask some more. Thanks everyone.