If the bank is working on a HMDA reportable loan request and regardless that we have or have not made a credit decision, and we never hear from the customer again...how is this coded? All the Q&A's I've read about Withdrawn or Denied coding relates to customers that have expressly withdrawn their application. We have applicats that just never return phone calls during the origination process. What do we do with these in relation to putting them on the LAR?

Thanks in advance.

Without knowing your exact process this sounds to me like you have incomplete applications and would either need to process them as denials for an incomplete application or send them the notice of incompleteness and treat them as closed for incompleteness if they did not respond by the stated time.

Assuming it's a consumer request, we underwrite the application when it's received. If we don't have enough information to underwrite, we'll deny for incomplete application if no response to verbal requests within 3 days.

If underwritten and denied, we send an AAN and report as denied. If approved, and we don't hear back from the applicant within x days, we'll send a 'notice of incompleteness' for verifications, etc. If no response by the end of the time given in that notice, we report as incomplete for HMDA.

If approved and no further verifications, etc are needed, we'll hold open for xx days, then close out the file and report as approved not accepted.