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#2153725 - 11/15/17 07:41 PM HMDA/Weird one....
JRosette Offline
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Joined: Jan 2016
Posts: 17
I have an ‘action type’ question. To better explain this weird scenario I’m using imaginary loan amounts. Borrower requested a loan amount = 120K on original application. Gets approved 120K per commitment letter. All documentation in the file speaks to 120K. Then…adverse action notice has loan amount = 125K; and states we can/will proceed with a loan amount for the 120K ?!
So we email the loan officer who said that somewhere down the line the loan amt. changed to 125K (no documentation to support that) and we were technically countering with 120K. He also mentions that he thinks it should be withdrawn as the borrower decided to go with a heloc.
This is convoluted I know, please let me know if you require any additional information to help me.

Thank you!

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#2153950 - 11/16/17 07:52 PM Re: HMDA/Weird one.... JRosette
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,351
Document the file with the officer's written response to your email....that the loan amount applied for was changed to $125,00 by the applicant.

I think it's a denial. A rejected counteroffer is a denial. You could not have made the loan at the requested $125,000.

If this is incorrect, I suspect I will be "shot down."
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#2153951 - 11/16/17 07:54 PM Re: HMDA/Weird one.... JRosette
raitchjay Offline
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Posts: 9,108
OK
Sounds like it got originated as a HELOC. If you don't report your HELOCs (or even if you do), i don't guess i understand the issue.
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#2153953 - 11/16/17 08:01 PM Re: HMDA/Weird one.... JRosette
raitchjay Offline
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Joined: Oct 2009
Posts: 9,108
OK
ETA: If this were here, i would advise simply amending the previous application to show a change to a HELOC. Thus, there would be only one application to deal with (not a "withdrawn" one and an "originated" one).
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#2154367 - 11/21/17 03:35 PM Re: HMDA/Weird one.... JRosette
JRosette Offline
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Joined: Jan 2016
Posts: 17
thank you all for your responses, much appreciated. The heloc may or may not go through, so our compliance dept. (i work in loan ops) advised us: denial w/ a loan amt equal to what was requested on the original app. : 0

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