Banker's Compliance Consulting Blog

HMDA: Approved But Not Accepted

Written by David Dickinson | May 1, 2026 9:00:40 PM

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.

Published 2026/05/01