We recently had two applications for refinance/consolidation loans where the applicants didn't know how much they wanted to borrow. According to the loan officer, both weren't sure at the time of application what debts they were going to pay off. One applicant withdrew his application and the other applicant was denied for incompleteness because he stopped responding to the loan officer.

In both cases, I think that we had an application for a covered loan under Regulation C. They may not have been complete applications for Reg B or TRID purposes, but I believe that we need to report these on the LAR with no loan amount. And just make sure that our file clearly explains why we don't have one.

Does this sound like the appropriate action to take?

Without a loan amount , it sure sounds more like a pre-qual to me.

2. Prequalification. A prequalification request is a request by a prospective loan applicant (other than a request for preapproval) for a preliminary determination on whether the prospective loan applicant would likely qualify for credit under an institution's standards, or for a determination on the amount of credit for which the prospective applicant would likely qualify. Some institutions evaluate prequalification requests through a procedure that is separate from the institution's normal loan application process; others use the same process. In either case, Regulation C does not require an institution to report prequalification requests on the loan/application register, even though these requests may constitute applications under Regulation B for purposes of adverse action notices.