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#1721407 - 07/19/12 12:19 AM CRA - Action Date?
T_CPB Offline
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Joined: May 2012
Posts: 1
I am struggling to figure out the definition for "Action Date".
I want to make sure we are reporting the correct date; however, I am being given different answers.

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CRA
#1721410 - 07/19/12 02:53 AM Re: CRA - Action Date? T_CPB
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
For a new loan it is the origination/note date. For a renewal/refinance it is the same..new note date.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1721483 - 07/19/12 02:19 PM Re: CRA - Action Date? Kathleen O. Blanchard
Al Miller Offline
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Al Miller
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
There can be multiple dates, and consistancy is the key. When I worked for a mortgage factory, we used the date the last signature was notarized. Coincidently that also begins the rescission period, so that date could also be used for other purposes. FDIC had no problem with using that date.

Al
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Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.

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#1721504 - 07/19/12 02:57 PM Re: CRA - Action Date? T_CPB
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
I always found that more problematic with true residential mortgage financing that small business loans.

As Al said, be consistent. You might go with the date your bank records on it system as the "origination date" when you have multiple dates in a transaction.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1721566 - 07/19/12 04:33 PM Re: CRA - Action Date? T_CPB
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Pick one of these for each scenario and stick with it:

New business loan
1. Date of the Note
2. Date documents are signed IF you have documentation that shows it.
3. Date of Funding (be sure to keep a copy of the funding tickets such as the GL ticket, Cashier's Check, or wire transfer order, etc.)

Renewed business loan
1. Date of renewal document
2. Date renewal documents are signed IF you have documentation that shows it.
3. Date your system shows the renewal was processed and keep a copy in file that shows that.

Mortgage loan
1. Date of Note
2. Date of signing (highlight the date the deed was notarized)
3. Date of funding
4. Date of Settlement as shown on the HUD-1
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CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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