I am fighting a losing battle with our commercial lenders regarding Reg B and HMDA. It would appear that we only have an application if the deal originates. Otherwise, they are being treated as inquiries, often received from brokers, where we respond whether we would or would not be interested in the deal. I am told that they don't have enough information to send adverse action, and that we therefore don't have an application. I can quote the regulatory requirements to them chapter and verse - what I'm looking for are any practical solutions to this problem. How are other banks managing this?

How are other banks managing this?

They insist on an commercial loan application and have written agreements with any broker specifying the requirement for submissions.

whether we would or would not be interested in the deal

The more common definition of this is pre-screening applicants. You are headed for a fair lending, HMDA and Reg. B train wreck.

The days that commercial lenders get to ignore regulations is long past. Management needs to bring them into the 21st century and quickly.

You have a management problem, not a lender problem. If management tells them the rules and measures them accordingly, they will perform. Otherwise, they are being rewarded for bad behavior, which encourages non-compliance.