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Thursday, July 14, 2016

HMDA: Date of Action Taken

QUESTION
We have been scrubbing our HMDA-LAR. In the course of our review, we became aware of the fact that there are different timing features involving the date of action for so-called “other actions.” What is the date of action taken for other actions?

ANSWER
The date of action taken does differ on the basis of several categories. In general, the following categories constitute differing ways of construing the date of action taken based on certain categories.
  • Purchase of loans: the date of action taken is the purchase date.
  • Loan application or preapproval denied: the date of action taken is the date the institution takes the action or the date the notice of action taken was sent to the applicant.
  • Application withdrawn: (1) if the withdrawal is not in writing, the date of action taken is the date the institution receives the applicant’s express withdrawal; and (2) if the withdrawal is in writing, the date of action taken is the date shown on the notification from the applicant.
  • Application closed for incompleteness: the date of action taken is the date the institution takes the action or the date the notice of action taken was sent to the applicant.
  • Preapproval approved but not accepted: the date the institution takes the action or the date the notice of action taken was sent to the applicant is the date of action taken.

Jonathan Foxx
President & Managing Director
Lenders Compliance Group