Answer:
First part. No. See page 10 of the 4/2/10 FAQs Q&A # 29.
Second part. If the request meets the definition of a home purchase, home improvement or a refinancing you have a loan subject to HMDA reporting regardless if it turns out to be "viable" or not. If it doesn't then you have a denial to report.
First published on BankersOnline.com 1/24/11