Which action taken code should HMDA applicable non originations other than adverse actions be given? In the past many have ended up with code 4 withdrawn. However the HMDA Getting it Right book says to use code 4 withdrawn only when the application is expressly withdrawn by the applicant before a credit decision is made, and usually we make the credit decision quite quickly since we use credit score decisioning. In these cases I believe they should be in code 2, approved but not accepted if the application was approved, but the loan was not made. Is that correct?
It really just depends on the situation with the loan to determine what you need to select.
If you haven’t made a credit decision (denied or approved) and the customer withdraws before you’re able to make a decision, then yes, it’s a “4 – Withdrawal”.
If you’ve approved the customer and then they decide to withdraw then it’s considered an 2 – APNA or “Approved Not Accepted”.