ANA or denial

Applicant was approved for a loan, all closing requirements met, and two days before closing the applicant requests a change in terms. We could not approve the requested change but were still willing to move forward with what had been approved. Applicant did not want to move forward. Do we report as ANA or is it a denial? Or is it both - ANA for HMDA and denial needing an AAN for Reg B?

Applicant amended their credit request - you denied the amendment and they did not accept your counter to continue with the original terms. IMO it's a denial.

That's how I'd treat it as well.

Dan laid it out well. The fact that they were approved initially but not based on their modified request for the loan doesn't change that. They didn't request a second loan, and the bank denied what was on the table/request.

Thanks everyone for the feedback.