Do Commitment Letters qualify as a Preapproval?

Question:

Although we have no formal Preapproval program, we do have mortgage loan officers that will provide commitment letters to an applicant if requested. Does this qualify as a Preapproval?

Answer:

If you allow or permit a loan officer to issue a letter of commitment, you have a business practice that provides written commitments. It's important to understand that this could create a "qualified" preapproval program subject to HMDA reporting and all preapproval applications would be reportable - NOT just those where the officer opted to provide a commitment letter.

Vendor:

Centrax