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Reasons for Denial – HMDA 2018

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  • March 28, 2018 at 10:35 am EDT #12706
    tressa
    Participant

    If a FI uses specific reasons for denial that are NOT on the REG B sample form, such as “delinquent credit obligations” and “delinquent credit history”, should code 3 be used for both reasons or should Code 9 “Other” be used and delinquent credit obligations and delinquent credit history entered in the reason(s) for denial conditional free form text field?

    March 28, 2018 at 1:28 pm EDT #12711
    jholzknecht
    Keymaster

    Paragraph 4(a)(16) of the Official Interpretations indicates that Code 3 would be the appropriate code for both of the reason mentioned in your question.

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