We received an application for a homestead purchase on “Property A”. The applicant did not have a contract for “Property A”. The LE was provided and signed by the applicant, including the intent to proceed. Before we were able to approve the loan for “Property A”, the applicant informed us he changed properties, so “Property B” enters the picture. Two days later the applicant comes into the branch and wants to change the loan term from 15 years to 30, and states he did not get the contract on “Property B” and was going to continue looking for a property. The loan got approved later that day with no property address. The applicant continued to shop around for another property with no luck, and decided to cancel the loan request.
How should I treat this application for HMDA purposes? Would you consider this application a PreQual, and not report, since it ended with no property address? Or, should I report two records, one for each property (A & B), both being withdrawn since the loan was not approved at the time the two properties were removed from the loan request, and then treat the applicant’s withdrawal as a PreQual since there was no property address at that time? If I report two records, that will look like he requested two loans, and he didn't, he only requested one loan.
Any help or guidance you can provide will be greatly appreciated.