I have an application that was withdrawn by the applicant before we approved the loan request. The application was taking as a home purchase for $600,000.00. We were needing the applicant’s financials. Once we received the financials, the customer changed the loan amount to $1,000,000.00 to do some improvements to the new home and added his current home as collateral to support the new loan amount with intentions to pay down the loan once the current home sold. 3 days later he withdrew his application due to contract issues with the seller. I’m having trouble figuring out what loan amount I need to report…the $600,000.00 or $1,000,000.00?

Sounds like it changed to temporary financing [bridge loan] and not reportable, or was he just going to make a principal reduction on a permanently financed loan and a collateral release post closing? If the later, then I'd go with the last request of $1MM. I imagine you re-disclosed due to a CC at that amount didn't you?

RR Joker, yes, it was going to be a principal reduction with a release for the old home once it sold, and yes, a new LE was prepared due to the CC.
My confusion is with the reg stating that an application that was denied, closed for incompleteness, or withdrawn, report the amount initially requested.
Even though the applicant initially requested home purchase for $600K, he changed his application to purchase and improve for $1MM before any action was taking. I too, believe it should be the $1MM, but that statement from the reg makes me question it.

I say it will be the $1MM based on full disclosure

Maybe others will come in to confirm [or deny] it !

3. Covered loan amount—preapproval request denied, application denied, closed for incompleteness or withdrawn. For a preapproval request that was denied, and for an application that was denied, closed for incompleteness, or withdrawn, a financial institution reports the amount for which the applicant applied.

The word "initially" does not appear in this section. The borrower applied for $600,000 then they increased their request and applied for $1MM. You report the $1MM which was the amount applied for at the time of the withdrawal.



The "initially" requested cite is for an unaccepted counteroffer.

1. Covered loan amount—counteroffer. If an applicant accepts a counteroffer for an amount different from the amount for which the applicant applied, the financial institution reports the covered loan amount granted. If an applicant does not accept a counteroffer or fails to respond, the institution reports the amount initially requested.

Ah, thank you Dan for clearing up the confusion for me. I appreciate yours and RR Joker's insight.

Hi Dan - Reading this thread, I am having an 'ah-ha' moment. Please reiterate for me, or confirm my thinking from reading your post above...

If/when an applicant requests changes to the loan amount, and the application is ultimately terminated by means above, the FI reports the Loan Amount at the time of termination?

Our procedures require the loan amount to be reset to what the applicant originally applied for.

If/when an applicant requests changes to the loan amount, and the application is ultimately terminated by means above, the FI reports the Loan Amount at the time of termination?

If the "termination" is taken on a denied preapproval request, denied application, a closed for incompleteness or a withdrawal then you report the loan amount requested at the time of the "termination". This is assuming the change in the loan amount was requested by the applicant and before the "termination" took place.

For an unaccepted counteroffer the original loan amount requested is reported.

I'm embarrassed to say it...I'm mind-blown. Auditors have been beating me up for YEARS if my FI did not report the initial amount. But maybe I didn't have a good defense in procedures because of the key word 'initial.'
Thanks, Dan! I appreciate you responding quickly!