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#2289774 - 10/16/23 09:02 PM Loan Amount for Withdrawn Application
LSB HMDA Offline
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Joined: Feb 2023
Posts: 17
Please advise on the following situation:
Borrower applied for a loan and provided us with all of the information for a completed application. We got prelims out using the original loan amount the borrower provided. The borrower then decided that they no longer needed to borrower as much as they had originally requested and asked to lower the loan amount. A few days after the loan amount change request, the borrower withdrew their application (prior to final docs being done). Now, we aren't sure which amount to report for our HMDA loan amount. Do we use the loan amount that was originally requested as that is what is showing on our prelim docs? Or do we report the loan amount as it was at the time of withdrawal?

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#2289784 - 10/17/23 07:13 AM Re: Loan Amount for Withdrawn Application LSB HMDA
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
If the lower loan amount did not involve a counteroffer and no credit decision was made, then you would report the original loan amount.

Official Interpretation
Paragraph 4(a)(7)
1. Covered loan amount—counteroffer. If an applicant accepts a counteroffer for an amount different from the amount for which the applicant applied, the financial institution reports the covered loan amount granted. If an applicant does not accept a counteroffer or fails to respond, the institution reports the amount initially requested.

3. Covered loan amount—preapproval request denied, application denied, closed for incompleteness or withdrawn. For a preapproval request that was denied, and for an application that was denied, closed for incompleteness, or withdrawn, a financial institution reports the amount for which the applicant applied.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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