In the HMDA Getting It Right the directions for application date call for consistency. It states
Paragraph 4(a)(1).
1. Application date—consistency. In reporting the date of application, an institution reports the date the application was received or the date shown on the application. Although an institution need not choose the same approach for its entire HMDA submission, it should be generally consistent (such as by routinely using one approach within a particular division of the institution or for a category of loans).
We use the date that is shown on the application. It prints from the LOS when the lender inputs the application and submits it for processing. Typically this date is the most accurate. However, I am looking at one loan where the application date is one thing, and the credit bureau is dated before that date. When questioning the lender, they mentioned that the request for credit was the date that the credit report was pulled, but the consumer was hesitating as far as what product they wanted. So a couple of days later, they decided, the lender completed the application and the date printed on the app. My thought is that the date of the credit report is the most accurate. However, would it be wrong to use the date printed on the application in this case? If we consistently pull the date from the application and its typically accurate, why would an auditor or examiner even look at the credit report?
Am I overthinking this?
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