[kcco]

Loan officer took a real estate application on 6/6. Told the customer the approval would depend on the appraisal. Well, technically, the approval ALWAYS depends on the value of the property. Before the appraisal was completed, the customer calls and withdraws his request. How do we handle this? Is this just a withdrawal? Or conditional approval? Should any kind of adverse action be sent? Etc etc

[kcco]

Also, how should this be reported for HMDA?

[rcooper]

In my opinion, it seems to me this was said in passing without a credit decision being made as part of your process rather than saying “you’re conditionally approved based on the appraisal.” If that is true then I would consider this withdrawn for both regulations and no adverse action is needed.

[jholzknecht]

I assume that an appraisal is part of the information that your bank regularly obtains and considers in evaluating applications for the amount and type of credit requested; therefore you did not have a complete application. A notice of action taken is not required until you have a completed application.

I agree with Robin’s conclusion that this should be handled as a withdrawn application.

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