*How are other banks handling applications that do not close by the time the approval expires; but might still originate someday?* Our approvals are good for 90 days. A couple times a year, we have a loan that is not closed in that 90 days and the loan has to go back through underwriting and get re-approved. We pull new credit, get new financials, etc. We currently have one in process that was applied for in November, approved in December, and the approval expired in March. It will not close until at least June. In my opinion, this should be reported now as 'approved and not accepted' since the client did not accept our loan within the specified time; (per paragraph 4(a)(8)(i)) And the client is free to apply again and get approved again whenever they are closer to ready. My opinion is that anything other than this process would make it difficult to handle things like action dates, year-end transitions, etc. How will I know if a file needs reported or not if I'm not sure if the final action has happened when the approval expires? However, one of our LOs is extremely opposed to this idea and so I thought I'd reach out and find out how other banks handle similar situation. Does an expired approval mean that the loan file is done? Or can it continue on for an infinite amount of time post-approval and be resurrected (or not!) at a later date?

Our approvals are for 120 days which coincides with document expiration for Freddie. If the applicant does not close the loan within that 120 days we will report it as Approved but Not Accepted. If the applicant reapplies at a later date we treat it as a new application and process it as such and we report it as a separate transaction on our LAR.

However, one of our LOs is extremely opposed to this idea

A MLO can certainly voice their opinion but they do not dictate our procedures.

From the GIR

3. Application date—reinstated application. If, within the same calendar year, an applicant asks
a financial institution to reinstate a counteroffer that the applicant previously did not accept (or
asks the institution to reconsider an application that was denied, withdrawn, or closed for
incompleteness), the institution may treat that request as the continuation of the earlier
transaction using the same ULI or NULI or as a new transaction with a new ULI or NULI. If the
institution treats the request for reinstatement or reconsideration as a new transaction, it reports
the date of the request as the application date. If the institution does not treat the request for
reinstatement or reconsideration as a new transaction, it reports the original application date.

Thanks - I appreciate the response.

Any more thoughts on how this is done at other banks?

We have a similar process to Dan but with shorter time frames on the consumer side. On the commercial side, we have a much more flexible application process, and HMDA is in fact a nightmare, but volume is very low. I can't even imagine allowing that on the consumer side or any side with significant volume.