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#2290459 - 11/07/23 03:35 PM Preapproval withdrawn with address
JoAnne S Offline
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Joined: Aug 2020
Posts: 17
First, I know that a withdrawn preapproval (with TBD Address) is not reportable. We are having a discussion regarding preapprovals with subsequent property identification and whether they are reportable.

Scenario: Application for preapproval received 10/13. Property identified on 10/17. On 10/18 applicant withdrew application because of mold issues with the property. No appraisal or underwriting was done.

I say this application is now reportable as withdrawn with preapproval marked as 1

Others say report as withdrawn but mark preapproval as 2

And others are saying not reportable because withdrawn preapprovals are not reported.

Which is correct?

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#2290462 - 11/07/23 03:54 PM Re: Preapproval withdrawn with address JoAnne S
Truffle Royale Offline

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Joined: Jul 2003
Posts: 17,392
Assuming you have the five other pieces of information, it is my understanding that once you have an address, it's no longer a pre-approval. It becomes an application for both TRID and HMDA. I would would mark it as a preapproval yes for HMDA.
Last edited by Truffle Royale; 11/08/23 03:11 PM. Reason: hmdagal answers this correctly below.
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#2290469 - 11/07/23 05:06 PM Re: Preapproval withdrawn with address JoAnne S
hmdagal Offline
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hmdagal
Joined: Dec 2002
Posts: 3,841
Once you have a property address this becomes a full application and would be reported as withdrawn. Per the commentary, the preapproval code would be '2':

2. Scope of requirement. A financial institution reports that the application or covered loan did not involve a preapproval request for a purchased covered loan; an application or covered loan for any purpose other than a home purchase loan; an application for a home purchase loan or a covered loan that is a home purchase loan secured by a multifamily dwelling; an application or covered loan that is an open-end line of credit or a reverse mortgage; or an application that is denied, withdrawn by the applicant, or closed for incompleteness.

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