HMDA: Approved But Not Accepted

Both the Equal Credit Opportunity Act (Regulation B) and the Home Mortgage Disclosure Act (Regulation C) provide rules as to how institutions are to treat credit applications. While both regulations promote fair lending, they don’t always line up. For instance, HMDA reporting institutions must report certain data from certain applications to the government on a HMDA Loan Application Register (LAR). One of these HMDA data fields is the Action Taken on the application. So, for example, whether a loan was originated, or the application was denied or closed for incompleteness. One option for action taken in HMDA is “approved but not accepted”, yet Regulation B doesn’t address this. In many cases, you might even have a denial for Regulation B but it will be “approved but not accepted” for HMDA. This difference often leads to confusion.

Dave explains more in the video.

HMDA Resources!

Published 2026/05/01

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.

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