Consistency Is Key To HMDA Reporting Of Application Date

HMDA Alert Getting It Right 2020

Under the new HMDA regulations that will take full effect in 2018, the Application Date is one of the HMDA reporting data points that will not change. Your financial institution will either report the date that the application was received or the date that is listed on the initial loan application. While the rule gives the institution leeway to choose which to report, the method should remain generally consistent throughout the entire reporting process.

How an institution treats a loan application can also effect which date is reported. An example of this is when within the same calendar year, the applicant asks to reinstate a counteroffer that had been previously rejected or when the applicant asks the lender to reconsider an application that had been denied, withdrawn, or incomplete. The institution has two options. It can consider it a continuation of the previous loan, in which case the original application date should be reported. Alternatively, it can also be treated as a new transaction, making the date of the request for reconsideration the date that is reported.

Figuring out the application date can be relatively easy for consumer applications; however commercial loans can be more difficult. For these types of loans that are HMDA reportable, it can be hard to determine which date to report as applications are not necessarily required.  One method that could be used by an institution for HMDA reporting of commercial loans is to report the date that the loan request was received.

Remember, consistency is key when reporting the application date.

 

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