We recently discovered that we have approx. 20 applications that for reasons I won't go into fell into a black hole and were not reported. We have all the information for HMDA reporting to file an amended LAR except action taken and action taken date. The only viable options for action take are either withdrawn or incomplete, but we have no documented communication from either the borrower or the loan officers. The loan officers are no longer here to answer questions. Are we better served to guess on action taken and date than to not report these? Any advice is appreciated - and yes, steps have been taken to prevent this in the future.