So, Brock are you saying that we wouldn't need to report the application since it's not the full 1003? Guess I've missed the boat on that one!
No you missed nothing. Whether the request is on a napkin or a 1003 it's still an application if you have all the necessary information.
Here's my take on Internet applications:
1. If your application program allows them to "submit" the application without all necessary information then:
a. Purchase request - if you don't have all 6 pieces of information you don't have an app for RESPA disclosures but you would have an incomplete application for Reg B and must either deny the application for being incomplete or send the notice of incompleteness. Calling them requesting the information and them not providing the information is not IMO a withdrawal. You won't process the application without the information so if they don't provide the information you're not going to process the request, IOWs you're denying the request due to the missing information.
b. Refinances - you may not have all the required information for RESPA but more than likely you will have the necessary information that would make it subject to HMDA plus the above comments concerning Reg. B.
Not sure why wanting to refinance a home equity lien has anything to do with you having an application. The only thing that may affect is which department would process the request.
PS. If you didn't pick up on it, I'm not a big Internet application fan for mortgage loans. I view them as a necessary evil!!!