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#486898 - 01/20/06 08:18 PM HMDA Question
OldSchoolBanker Offline
Platinum Poster
Joined: May 2005
Posts: 662
FL
We do not have a formal preapproval program as specifically defined in Reg C. We do accept applications for purchase where no property has been defined and run credit and DU and issue commitment letters subject to income/asset verifications and other typical property related items.

I have a few of these types of appliactions where the borrower has said cancel the loan, before they ever find a property. I am classifying these as Withdrawn and since I do not have a property, I do not have complete geocoding info.

Is it okay to file the HMDA LAR with missing geocoding? Do I just indicate NA?

Thanks!

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Lending Compliance
#486899 - 01/20/06 08:25 PM Re: HMDA Question
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Since you do not have a qualifying pre-approval program these sound like they would be pre-qualifications and pre-qualifications are not reportable.

However, if they meet the pre-approval criteria and there is no identified property then you report NA in the property fields.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#486900 - 01/20/06 08:53 PM Re: HMDA Question
OldSchoolBanker Offline
Platinum Poster
Joined: May 2005
Posts: 662
FL
Thanks Dan. They actually would not meet the full preapproval criteria. Guess I would kick them out of the HMDA LAR as prequals
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Old School Banker

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