I know this is sometimes a hotly debated topic as to whether or not a loan can be run through AUS and still withdrawn. Not trying to rehash that so just assume that an AUS is not a true underwriting decision thus a loan can still be withdrawn after it has been run (which I think is supported by discussion in the HMDA final rule).

You would still report the AUS on a withdrawal, correct? Also, what if you run LP and DU would you report both?

I am trying to get this figured out as well. If an AUS was run, is it considered a credit decision?

If not and the file is withdrawn or closed for incompleteness and the file never actually went through underwriting do we report the credit score, CLTV, DTI etc.,etc as N/A?

Any help is greatly appreciated.

AUS is used to help make a decision, but it isn't the only factor. I can't tell you if you made a credit decision yet. If you made a decision, report the data. If you didn't make a decision, you report NA for these:

Credit Score:
If a file was closed for incompleteness or the application was withdrawn before a credit decision was made, the financial institution complies… by reporting that the requirement is not applicable, even if the financial institution had obtained or created a credit score for the applicant or co- applicant. For example, if a file is closed for incompleteness… the financial institution complies… by reporting that the requirement is not applicable, even if the financial institution had obtained or created a credit score for the applicant or co-applicant. Similarly, if an application was withdrawn by the applicant before a credit decision was made… the financial institution complies… by reporting that the requirement is not applicable, even if the financial institution had obtained or created a credit score for the applicant or co- applicant. [Commentary to §1003.4(a)(15) #4]

CLTV:
Report “N/A” if a credit decision was not made (i.e., notice of incompleteness, withdrawn before credit decision). [Commentary to §1003.4(a)(24) #3]

DTI:
Report “N/A” if a credit decision was not made (i.e., notice of incompleteness, withdrawn before credit decision). [Commentary to §1003.4(a)(23) #3]

Dan, to my original question would you report the AUS and AUS result? I agree with what you would report if a credit decision was not made for Credit Score, CLTV, and DTI. I just can't determine when a credit decision has not been made but you ran AUS what you would report. Perhaps I am just overlooking it somewhere.

Not sure how I got pulled into this conversation but the Reg. says to report the AUS used in evaluating the application so if an AUS was pulled we report it and its results regardless of the application's disposition.

I assume you're asking me (Dave, not Dan). Sorry, I forgot to comment on AUS in my original response. The Commentary to §1003.4(a)(35) #1(ii) states:

Report …the name of the automated underwriting system used by the financial institution to evaluate the application and the result generated by that automated underwriting system. [§1003.4(a)(35)(i)] Report …the name of the AUS used… to evaluate the application and the result generated by that system, regardless of whether the AUS was used in… the …underwriting process.

The only time we can report NA is for manual underwrites (where an AUS was not used) or when BOTH the applicant AND co-applicant (if applicable) are not natural persons. [Commentary to §1003.4(a)(35) #4 and #6]

Therefore, I believe you need to report the AUS data if you ran it - whether you made a decision or not.

Sorry, I meant David. Just trying to keep you on your toes. Thanks for confirming.