Question & Answer

Question: We just received a mail-in application for which the applicant used a general form. It did not have information for type of loan and loan amount on it. Several days after mailing in the application, the applicant called to withdraw the application. We were unable to obtain the loan amount and loan type information for HMDA reporting. How should we handle this?

Answer: It is always a better practice to include a questionable application on the LAR than to omit it. In this case, the application should be entered as "withdrawn by applicant." If the software will accept the codes, use "n/a" for the information you do not have. Even though the information is partial and missing information is critical, the fact is that the bank received the application and should maintain a record of it. For this purpose, Regulation B requires record retention for 25 months.

Copyright © 1998 Compliance Action. Originally appeared in Compliance Action, Vol. 3 , No. 5 & 6, 4/98