HMDA: Approved But Not Accepted
When it comes to HMDA reporting, one of the action taken codes that gives institutions some trouble is Code 2 - Application Approved but not Accepted (ANA). The reason is that “approved” means the applicant is fully approved (i.e., all verifications have been received and the applicant is cleared to close). In other words, the applicant has met all underwriting and creditworthiness conditions. These are different than conditions related to the property (aka customary commitment and closing conditions). Then to top it all off what you are required to report for HMDA might not match up with the action taken for Regulation B (Equal Credit Opportunity Act) reasons.
David explains more in the video.
2024/11/25
David Dickinson
David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.