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Non Originations

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  • #2606
    TheBank
    Participant

    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 In the past many have ended up with code 4 withdrawn. However the HMDA Getting it Right book says to use code 4 withdrawn only when the application is expressly withdrawn by the applicant before a credit decision is made, and usually we make the credit decision quite quickly since we use credit score decisioning.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?

    #3034
    dmurray
    Participant

    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”.

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