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A lender receives a pre-application inquiry from a borrower who provides their name, income, and property address but does not submit a formal application. Six months later, the same borrower submits a complete application. How should this be reported under HMDA?

Correct Answer

B) Report only the formal application since the inquiry was incomplete

Under Regulation C, only applications that result in a credit decision or are withdrawn by the applicant are reportable. Pre-application inquiries that do not result in an application are not reported separately. The formal application is the reportable event.

Answer Options
A
Report both the inquiry and the application as separate entries
B
Report only the formal application since the inquiry was incomplete
C
Report only the inquiry since it occurred first
D
Combine both into a single application entry with the inquiry date

Why This Is the Correct Answer

Under Regulation C, only applications that result in a credit decision or are withdrawn by the applicant are reportable. Pre-application inquiries that do not result in an application are not reported separately. The formal application is the reportable event.

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