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#2071521 - 03/29/16 11:04 PM Application date obsession
Bec Offline
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Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
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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#2071559 - 03/30/16 01:20 PM Re: Application date obsession Bec
ComplyGuy Offline
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Joined: May 2015
Posts: 302
The guidance says you can use either the date the application was received or the date on the form. If your institution typically uses the date on the form, I think it would be fine to use in this instance as well. Below is from the appendix A.

2. Date Application Received.
Enter the date the loan application was received by your institution by month, day, and year. If your institution normally records the date shown on the application form you may use that date instead. Enter “NA” for loans purchased

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#2071589 - 03/30/16 02:37 PM Re: Application date obsession Bec
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,765
Central City, NE
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.
Since the applicant couldn't decide what product they wanted, I think the loan officer is correct with waiting until when "they decided" to record the application on your system. I have no problem with that date for HMDA.

If you're questioning whether you can have a credit report date prior to an application date, the answer is "yes" as shown by your example. While there's a high correlation between credit reports and applications, it's not absolute. Another example would be a prequalfication when the lender pulls the applicant's credit report to get debt info and FICO, prequalifies them and they later they find a house. The credit repot date is going to be much sooner than the application date for HMDA.

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#2071628 - 03/30/16 04:12 PM Re: Application date obsession Bec
Bec Offline
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Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
Thank you all.

Very appreciated. smile
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