HMDA: Denied or Approved Not Accepted?

Question:  We approved an applicant, but before closing it was determined that legal access to the property was not obtained (all owners of surrounding Screen Shot 2019 05 30 At 8.57.09 AM 300x172properties did not sign easements).  For HMDA, would this be a denial or approved not accepted?

Answer:  If you ultimately denied the application because of the access issues, you would owe the applicant an adverse action notice for Regulation B purposes.  However, for HMDA this must be reported as “Approved but not Accepted”.  HMDA wants to know how the applicant was treated while Regulation B wants to know how the application was treated.  In this case, the applicant was approved but the application was denied.

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