If the credit decision has been made, and we provided early disclosures and the borrower withdraws, how is this coded for HMDA? Are they action type 2?

code 4 - see page A3 of GIR

I agree...."approved but not accepted." Applications can be withdrawn only prior to a credit decision being made. This definition differs from Reg B which states that an approved application that the applicant does not act upon within 30 days may be considered as "withdrawn."

But the credit decision was made before they withdrew.

I would code it a 2, approved but not accepted.

Question: Using City Girl's example, would HOEPA apply? I know rate spread doesn't apply, but I haven't yet seen anything about HOEPA and withdrawn apps.

Thanks.

On the HMDA LAR you would enter code 2 since the application did not result in a loan origination (page A-10).

Thanks, I completely missed that.....I need a day off. LOL