[kcco]

I have a file that was “closed for incompleteness” due to the letter for incompleteness in the file. However, the letter states “the following information is needed..additional road right of way to have survey completed to separate mobile home and house tracts”. Should this have been a denial? Since I have the letter as required by reg B do I report this as incomplete for HMDA?

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[rcooper]

I would have a conversation with the lender to better understand why the file was “incomplete” – that might answer your questions or it might identify an area where training is needed.

I believe, technically, since the notice of incompleteness was sent you may report this as the action taken. Again, you may need to have a training session with the lender on what constitutes a denial vs incomplete application – your research with this file will determine that.

[kcco]

Also, how would I report income? NA or what is in the file?

[Author]

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