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What's our decision for HMDA?

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We have a purchase mortgage application that was approved with all underwriting conditions met. In review of the title run it was discovered the seller could not convey a clear title to the property. We did send the borrower a Notice of Action for Incomplete Application giving 10 days for clear title to be received. For HMDA purposes would the Action Taken be Approved Not Accepted or Denial?

Being able to get clear title is a customary closing condition - Approved but Not Accepted.

First published on 12/18/2022

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