We do not disclose our preapprovals until they become “Live Loans”. When they are “Preapproved not accepted” they are showing up as “NC” in the rate spread field. It is my understanding they should be “NA” as we would not have a rate lock date or a last rate set date.
If the loan is approved but not accepted and Reg Z disclosures were given you would enter a rate spread based on the last disclosure provided.
You would only report NA on denials or if Regulation Z disclosures aren’t required to be delivered.
A Guide to HMDA Reporting:
Enter “NA” for:
Covered loans that are assumptions, reverse mortgages, purchased loans, or are not subject to Regulation Z, § 1003.4(a)(12)(i); Comment 4(a)(12)-7;
Applications that did not result in an origination other than approved but not accepted,
Where an application or a preapproval request is an Application under Regulation C, but for which no disclosures are required under Regulation Z, the Financial Institution reports that the data is not applicable.