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HMDA Reg C "Approved Not Accepted"-Which Amount

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Question: 
HMDA - Reg C In the HMDA GIR it is very clear that on loans that are declined or withdrawn, you report the loan amount based on what the terms the borrower originally applied for. For counter offers, it is very clear if the counter offer is not accepted, to report the original loan amount. I cannot find any reference on Approved Not Accepted. My example: Borrower applied for a refinance of $100,000 (no cash out). Later that day, I discovered that pay-off on existing lien is less than $100,000 and I requested that the loan amount be changed to $98,000. The loan was fully approved by the lender. The borrower decided not to refinance. We reported the loan as approved not accepted. What loan amount is reported? We did not approve the $100,000 and this loan amount would have created a cash-out with different guidelines. We fully approved the $98,000.
Answer: 

You approved a loan for $98,000 and not the $100,000 that was applied for. The customer did not accept the loan, you have a denial.

First published on BankersOnline.com 7/30/12

First published on 07/30/2012

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