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#2305943 - 02/10/25 07:49 PM Assumption "application" HMDA reportable?
Compliance Nut Offline
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Joined: Feb 2016
Posts: 246
If we have some assumptions that never actually panned out (so no written agreement accepting a new borrower, etc.), are they HMDA reportable? We don't really have assumption "applications" like a typical mortgage loan application. They are really more like inquiries at this point (where a family member wants to see if they qualify, etc.). Can we consider these pre-qualifications?

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#2305957 - 02/10/25 09:10 PM Re: Assumption "application" HMDA reportable? Compliance Nut
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,886
Bloomington, IN
If you never entered into a written agreement accepting a new borrower then there is nothing to report; however depending why they did not "pan out" you may owe an AAN under Reg. B.
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#2305958 - 02/10/25 09:13 PM Re: Assumption "application" HMDA reportable? Compliance Nut
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,424
Galveston, TX
"where a family member wants to see if they qualify"

How is that not an assumption application, written or not? No different than them saying that there is this 2023 Ford F-150 they want to buy, and I want to see if I can qualify for a loan. Pre-quals involve situations where there is no property identified, and they are asking for a ballpark on how much for which they might be approved.
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