TOPIC: Reg B

HMDA Reportable Loan Applications

Employee at a bank ($1.8BUSA)
Good morning everyone! 

I am in the process of reviewing our HMDA data for the 2020 submission. We use MortgageBot (Finastra) for both our LOS and online POS. I have come across several HE applications in our system that were entered online in our POS by the borrower. When the application was imported into our LOS and the Originator talked with the borrower they stated that the borrower selected the wrong product and really wanted a HELOC (we currently do not have to report HELOC's). Our current system does not allow you to change the product type, therefore the originator must start a whole new application. 

My first thought was that the HE application should be reported on the LAR as withdraw (4). I am getting questioned if this needs to be done as it was entered in error and when we do start reporting HELOC's we will be double reporting applications. I have been reading the reg. and I can't make heads or tails of how I should handle these applications. 

Can anyone shed some light on this for me?