What is the best way to handle TBDS that we need to clear out of pipeline in the following situation? Secondary market is winding down and will not be closing additional files. These TBDS are not denials but not necessarily withdrawals either. Some are probably following lenders but there is no list. Do we deny for incomplete application?

If these are true prequalifications they are not HMDA reportable so no HMDA issues. As long as no adverse action has been taken then there are no notification requirements under 1002.9.

How you handle stale prequalification requests is an internal business decision.