by Richard Insley:
re #1: Until an online applicant hits a "submit" button (or a similar triggering device), s/he has done nothing more than a traditional applicant who starts to fill out a paper application form and leaves it on the kitchen table. You don't consider the latter to be an "application." Based on identical logic, neither is the former.
by David Dickinson:
Re #2: You have a request for credit (an application). It may be incomplete, but you need to follow up with the applicants per §1002.9(c)(1).
Re: prequalifications: If you have approved the prequalification and the applicant stops providing information, technically, you do not need to send a notice of incompleteness (NOI). Refer to the Commentary to §1002.9(c)(1):
1. Exception for preapprovals. The requirement to provide a notice of incompleteness does not apply to preapprovals that constitute applications under §1002.2(f).
However, most institutions do provide a NOI to prompt the applicant and because this is a gray area.