For Denial/WD/File Closed for Incompleteness should the loan amount reflect the final action as reported to the customer or the initial application loan amount? If the applicant changed the loan amount (like a changed circumstance) and a Statement of Notice was sent to the customer with the final loan amount applied for wouldn't that be the amount recorded on the HMDA Lar?
I understand that under 1003.4(a)(7)(3) states that the loan amount reported is the amount for which the applicant applied for. However not using the correct loan amount could be a possible fair lending issue also.

Using the philosophy behind the covered loan amount, included in your cite, and counteroffers, what did the applicant apply for? If they applied for $X and later amended it to $X+1, they are requesting $X+1. If they requested $X and the bank was offering $X-1, and the applicant never accepted that offer, they're still at $X. If they accepted that amount but then failed to follow thru of some other requirements, substantiated by documenting their approval of the counteroffer, you're at $X-1. It is the covered loan amount you're after for this.
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